5. ATTACHEMENT J.8 – DEC REPORT USAID Ukraine AGRO IEE & Amendments Redacted.pdf
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This document appears to be an attachment to a USAID/Ukraine solicitation for a Harvest Activity. The solicitation is seeking proposals to implement USAID's Harvest Activity in Ukraine through a cooperative agreement. Key services required under the activity include assisting Ukrainian farmers and agribusinesses with increasing agricultural productivity and linking them to domestic and international markets. The anticipated period of performance is five years, with an estimated total value of $150 million. Proposals are due by January 31, 2023, with award of the cooperative agreement expected by April 30, 2023. The solicitation is open to U.S., non-U.S., and Ukrainian organizations with experience implementing agricultural development programs.
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DCN: 2019-UKR-031-004
USAID/Ukraine - AGRO IEE Amendment 2 1 EE.BEU Standard Form IEE.v3
US Agency for International Development (USAID) for Regional Mission to Ukraine and Belarus
Amendment #2 to the Initial Environmental Examination (IEE)
Activity Data
Activity Name: Agriculture Growing Rural Opportunities (AGRO) Activity
Assistance Objective: Inclusive, Sustainable Market-Driven Economic Growth
Program Area: EG 5. Private Sector Productivity
Country(ies) and/or Operating Unit: USAID/Ukraine
Originating Office: Office of Economic Growth Date: April XX, 2022
☐ Original IEE/RCE Original IEE LOP Start Date: FY2019
☒ IEE/RCE Amendment New Funding: N/A
IEE/RCE History DCN LOP End Date Total Funding ($)
Original RCE/IEE: 2019-UKR-031 11/24
Amendment 1 2020-UKR-079 11/24
Amendment 2 2019-UKR-031-004 11/24
Purpose of Amendment: To add illustrative activities and mitigation measures under Component 1
(Activities 1.16 – 1.17) and Component 3 (Activities 3.15 - 3.17)
Contract/Award Number (if known): 72012120CA00001
Recommended Environmental Determination (s):
☒ Categorical Exclusion ☐ Positive Determination
☒ Negative Determination ☐ Deferral
Additional Elements:
☒ Conditions ☐ Government to Government
☐ No Conditions ☐ Public International Organization (PIO) environmental and social policies and procedures applicable
☐ Local Procurement ☐ Sustainability Analysis (included)
☐ Donor Co-Funded x Climate Change Vulnerability Analysis (included)
Climate Change Vulnerability Rating: [Moderate]
1. Purpose of amendment
The purpose of this Amendment is to add illustrative activities and mitigation measures under
Component 1 (Activities 1.16 – 1.17) and Component 3 (Activities 3.15 - 3.17) of the AGRO Activity to address the immediate needs and restore the Ukrainian agricultural sector affected by Russia’s military invasion.1
2. Compliance of Ongoing Activities with IEE Requirements
Conditions of the original IEE and its amendment (DCN: 2019-UKR-031 and DCN: 2020-UKR-079) remain in effect. All ongoing activities under the program are performed in compliance with the IEE and its amendments. When drafting legislation and regulations, the implementing partners always encourage the assisted government authorities to integrate environmental considerations into the proposed legislation in line with the best international (EU compatible) approaches and practices.
1 This IEE amendment is prepared to address the adapted project’s activities to enable AGRO to meet the immediate needs of the Ukrainian agrosector and allow for implementation of the USAID approved immediate response plan. Yet, this IEE will also back the rapid deployment of any additional activities should the supplemental funding be granted.
ATTACHEMENT J.8 – DEC REPORT USAID Ukraine AGRO IEE & Amendments Redacted
LuciaSandefur Highlight
USAID/Ukraine - AGRO IEE Amendment 2 2 EE.BEU Standard Form IEE.v3
With this Amendment, all existing reporting requirements shall remain in place. There has been no change in the baseline environmental information.
2.1. Climate Change Vulnerability Analysis
Climate risk management (CRM) for this activity has been conducted in accordance with CRM for
USAID Projects and Activities, Mandatory Reference for ADS Chapter 201. CRM for the approved
Mission Country Development Cooperation Strategy (CDCS) was conducted at the country strategy-level, with the expectation that subsequent climate risk screening will occur as part of the development process for projects and activities (e.g., at the PAD and activity-level). Therefore, climate risks have been assessed at the activity level and results of this assessment are summarized in the table below.
The Climate Risk Screening and Management Tool for Activity Design for this activity is included in
Annex A.
According to USAID’s Climate Change Risk Profile for Ukraine (2016), an increase in average annual temperatures of 0.8°C occurred from 1991 – 2010 (compared to the 1961 – 1990 average). Further, a
0.5-degree C to 1.0-degree C increase in temperature is projected for Ukraine with increased overall temperatures by 2050 and higher rates of increase expected in the winter; seasonal and regional rainfall patterns are expected to change; and increased incidences of extreme weather events, such as floods and droughts are projected. Some key impacts that are likely to result from these projections are:
shifting agricultural production zones; decreased surface water quality and quantity; decreased energy efficiency and power supply interruptions; increased forest fire risk; and exacerbation of cardiovascular and respiratory diseases; reducing of the industrial fishing potential.
Of importance for AGRO, agriculture and related industries in the south and southeast of Ukraine are most vulnerable to current and projected droughts. The industrial sector leads to water withdrawal.
Precipitation is expected to decrease in the Forest-Steppe and Steppe eco-regions, decreasing mean annual runoff. Drought risk is expected to increase in the southern Forest-Steppe and Steppe zones.
Ukraine’s agriculture readiness for expected climatic changes is relatively low. Agricultural businesses have low levels of awareness of required actions. In the future, it will become necessary to account for climatic changes in production development plans, review the composition of agricultural crops in favor of those more resistant to climatic changes, adapt land-utilization structure, develop irrigation, and improve agroclimatic monitoring and prediction. At the same time, there is a possibility of reducing the climatic impact of these industries, e.g., through restricted plowing, protection of multi-year pastures, and use of waste biomass to generate heat and electricity. Maximizing drip irrigation and use of drought tolerant species will add to long term gains.
3. Description of new activities under the AGRO Activity
The goal of AGRO is to accelerate economic development of rural communities in highest need in the east and south of Ukraine through a better governed agricultural sector, to encourage more productive, modern, and profitable small and medium agricultural businesses that are successfully integrated into competitive markets both in Ukraine and internationally.
While AGRO’s goal remains the same, its strategy and specific activities required to achieve this goal have been significantly impacted by the humanitarian crisis unfolding in Ukraine after Russia’s invasion of Ukraine on February 24, 2022. Invasion caused a large-scale damage to the Ukrainian agricultural infrastructure, disruption to markets and food supply chains that likely to have significant impacts (both short- and long-term) on food security and agriculture-based livelihoods in Ukraine, specifically in rural communities, which are home to one third of the population (12.6 million people).
Since Ukraine is one of the major exporters of agricultural inputs (according to the Fitch Ukraine
Agribusiness Report, Ukraine’s grains account for 11.6% and 8.3% of global corn and wheat exports, respectively), the impact of the war will also go well beyond Ukraine.
With additional activities, AGRO plans to provide new interventions aimed at supporting food security and maintaining soft market infrastructure during the wartime, and more holistically apply a strategy that considers necessary interventions in the immediate and long-term economic recovery periods following the cessation of active hostilities. Where applicable, AGRO will shift its activities from
USAID/Ukraine - AGRO IEE Amendment 2 3 EE.BEU Standard Form IEE.v3 oblasts with active military actions to the safer regions of western and central Ukraine not occupied by
Russian forces
Additional activities under this Amendment will include interventions under Components 1 and 3 of the AGRO Activity.
Component 1: Agricultural Micro, Small, and Medium Enterprises (MSMEs) Productivity and
Market Access
The Activity will assist partners in target value chains to create new and recover broken market chains both in Ukraine and internationally. In current wartime conditions, there are immediate challenges caused by disruption to the inputs supply chain, including considerably higher costs/lower availability of fuel, plant protection materials/pesticides, veterinary pharmaceuticals and vaccines, seeds and seedings, fertilizers, spare parts, and agricultural machinery.
AGRO will support business relocation and start-up activities by working with regional and local partners in business and public sectors to assist agri-food MSMEs in relocation and setting up the operations in new locations and integrating into new value chains to help secure uninterrupted production and supply of food. AGRO will work directly with MSMEs, host regions and communities and business support organizations and use a comprehensive approach in addressing the relocation needs.
Thereby, additional activities under Component 1 will include:
Activity 1.16: Interventions that provide inputs and supplies to ensure food security for private and public sector partners (seeds and seedlings, animal feed, fertilizers, plant protection materials/pesticides, veterinary pharmaceuticals and vaccines). Activities will include educational programs, trainings, seminars, study tours, advisory and consulting assistance, information sharing, inputs and supplies purchase, reimbursement of inputs purchase, activities for connecting partners, and purchasing equipment for production.
Seeds and seedlings to be procured and utilized will meet the requirements laid out in the USAID
Mission Director-approved support for the identified commodities (per PD-15 Action Memorandum dated April 21, 2020 and “PD-15, ADS 225-Surplus Commodities and PD-71 Analysis – Impact of
AGRO and DCA Bank Lviv” Action Memorandum dated March 25, 2022) and subsequent updates.
AGRO will focus on procurement of non-treated seeds. However, the need for treated seeds may occur in the future. Although seeds that are pre-treated with pesticides are not considered pest-control products under the US Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), there are risks associated with treated seeds exposure. Therefore, should the need for the treated seeds arise in the future, AGRO will develop and follow relevant safety and impact mitigation measures.
Animal feed. Under this activity, AGRO intends to purchase animal feed (poultry: turkeys, ducks, chickens; animal livestock: cattle, goats, sheep, pigs) for different age groups and breeds in order to maintain its productivity throughout the growth process - from young age to becoming marketable. At different age stages poultry and animal livestock need different types of feed depending on their growth and feed level (pre-starter, starter, grower, finisher). Thus, the feed differentiates by breed and age groups.
Animal feed will be provided by certified producers/vendors both packaged and in bulk. Feed safety and quality will be confirmed by relevant certificates. AGRO will provide consultancy assistance on the feed use via qualified contractors. Waste management trainings for feed packaging waste will be provided, if needed.
Fertilizers to be procured will meet requirements of ADS Chapter 312 Fertilizer Financing Guidance and Organic Standards of European Unit and USA (National Organic Program). AGRO plans to procure:
- Mineral or chemical fertilizers containing one, two, three of or more of the following nutrients
- Nitrogen, Phosphorus, or Potassium (except for Ammonium Nitrate and Calcium
Ammonium Nitrate), Calcium, Magnesium, Sulfur, and/or micronutrients.
- Animal or plant-based fertilizers or soil amendments if they are not intended for use more than
40km from their point of origin, with confirmation of a reasonable level of phytosanitary safety
USAID/Ukraine - AGRO IEE Amendment 2 4 EE.BEU Standard Form IEE.v3
(i.e., that the product is composed of traditional local materials such as animal manure and plant residues and does not pose a great threat of transporting weed seeds or plant pathogens beyond the point of origin).
- Bulk or granular organic and mineral fertilizers, classified in the list of certified/approved ancillary products allowed for use in organic production, taking into account organic standards.
AGRO will ensure that the transportation, storage, and use conditions (including waste management) are aligned to the requirements of the product vendor/supplier and national regulations.
Pesticides. Activities dealing with pesticides will be implemented in compliance with provisions of the Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP) for Ukraine (DCN:2018-UKR-
044) and its subsequent amendments. The list of active ingredients (AIs) of pesticides to be procured by AGRO after PERSUAP amendment will correspond with the list of AIs recommended by
PERSUAP. Pesticides will be transferred only to the agricultural producers trained by the or other authorized bodies (e.g., industry associations, licensed providers, etc.) for pesticides handling and management and having qualified staff. All procedures will be implemented in accordance with PERSUAP provisions and national regulations.
Veterinary pharmaceuticals and vaccines. AGRO Activity will ensure that the manufacturer and/or wholesaler is approved in accordance with the requirements of ADS 312sae Pharmaceuticals and
Condoms, IV. Categories of Pharmaceuticals, B. OHA/SCH Approved Sources. All veterinary pharmaceuticals and vaccines will be US-manufactured and will be purchased from the trusted and responsible vendors from USAID-approved sources and
. No pesticide-containing pharmaceuticals and vaccines will be procured. AGRO will request documentation of the manufacturer’s standards and certifications as well as product
FDA/SRA approvals. In addition, AGRO will ensure that the transportation and storage requirements are clearly tailored and aligned to the requirements of the product. AGRO will conduct a visual inspection to ensure that the packaging/labeling was consistent with good manufacturing process standards and the ADS, and the shelf life meets the required parameters. AGRO will ensure appropriate records of all batches of the product, their distribution, destinations, and recipients. Only recipients with qualified veterinary and/or zootechnical staff and established and operating medical waste management system will be provided with veterinary pharmaceuticals and vaccines.
Activity 1.17: Interventions that support AGRO’s business relocation and start-up activities to assist agri-food MSMEs in setting up the operations in new locations and integrating into new value chains to help secure uninterrupted production and supply of food. Activity will include studies, information sharing, consulting assistance and trainings, legal support, technical assistance, relocation support, and equipment purchase.
Component 2: Access to Finance.
There will be no additional activities under Component 2.
Component 3: Better Policy and Enabling Environment for Small and Medium Agricultural
Enterprises
The Activity will partner with public and private sector stakeholders to develop more inclusive, transparent, and effective land regulation and agricultural policies that ensure food security under conditions of the martial law.
Additional activities under Component 3 will include:
Activity 3.15: Interventions to conduct studies with documenting war crimes, crimes against humanity, damages and losses inflicted by Russian aggression to the agricultural sector, landowners, and land users in order to hold the aggressor accountable. Activities will include studies and analysis, information sharing, and consulting assistance.
Activity 3.16: Interventions that support land decontamination from the war (including coordinating information sharing with humanitarian organizations focused on demining). Activities will include studies and analysis, consulting assistance, and equipment purchase.
Activity 3.17: Interventions that provide support for the by providing advisory services and technical support on the management of melioration systems during and after the martial law. Activities will include studies and analysis (including mapping), consulting
USAID/Ukraine - AGRO IEE Amendment 2 5 EE.BEU Standard Form IEE.v3 assistance, research, forums, conferences, study tours, information sharing, and equipment purchase including water efficient technologies and laboratory and IT equipment for studies and analysis.
3.1. Sustainability Analysis
AGRO will partner with the private sector to advance progress in areas that are most critical for development of the agricultural sector. This will catalyze the private sector as a driving force based on business incentives. In particular, effective, transparent, and corruption-free land management is an important prerequisite for businesses to invest in their growth and to create jobs. Establishing a fair and equitable agricultural land market is a powerful impetus for attracting investment in the sector.
Increased investment will stimulate development of areas with higher profit margins and more added value, e.g., orchards, berries, livestock, alternative poultry, aquaculture, and food processing.
Components such as scalable projects that demonstrate productivity gains; successful models for penetration of more competitive markets based on higher quality and market understanding; and concomitant outreach and communication campaigns, would help AGRO develop a critical mass of sector champions able to sustain sector development beyond U.S. engagement. Building on the local land management model developed and implemented by its predecessor activity, Agriculture and Rural
Development Support (ARDS), AGRO will focus on building the capacity and commitment of rural consolidated communities to create a better enabling environment for MSMEs, mobilize local resources, and thus increase living standards for poor rural citizens.
Technical assistance for private and public partners, including consultancy and advisory assistance, studies and analysis, inputs and equipment procurement will help to implement activities in compliance with legal and technical standards requirements, including proper assessment and mitigation of potential environmental impact.
New activities are focused on support of private and public partners during and after martial law and will allow ensuring the food security both for Ukrainian internal and international markets.
USAID/Ukraine/AGRO— IEE Amendment 2 6 EE.BEU Standard Form IEE.v3
Table 1. Defined/ Illustrative Activities and Recommended Threshold Determinations
Defined/Illustrative
Activities
Potential Impacts Mitigation Measures Recommended
Threshold
Determination
Component 1: Agricultural MSMEs Productivity and Market Access
1.16: Interventions that provide inputs and supplies to ensure food security for private sector partners and communities (seeds and seedlings, animal feed, fertilizers, plant protection materials/ pesticides, veterinary pharmaceuticals and vaccines)
Activities will include educational programs, trainings, seminars, study tours, advisory and consulting assistance, information sharing, inputs and supplies purchase, reimbursement of inputs purchase, activities for connecting partners, and equipment purchase
- Potential environmental impact depends on the character and location of the planned activity. Further analysis of each individual activity is needed to quantify potential impacts on a case-by-case basis. However, following potential negative environmental and social impacts are associated with the implementation of activity 1.16.
Fertilizer impacts vary depending on the type and application of the fertilizers. Some fertilizers have dual action as pesticides. Impacts may include:
• Surface water and groundwater contamination:
Over-application can lead to runoff into surface waters or leaching into groundwater, particularly in sandy soils. Even small amounts of over-application of phosphorus can lead to harmful algal blooms in waterways which reduce oxygen and kill instream fauna
• Human health hazards: Touching some fertilizers with bare hands may cause skin irritation and ingesting it may be poisonous. Inappropriately stored fertilizer is a health hazard. Phosphorus fertilizers also commonly contain cadmium which is toxic to humans. Children exposed to contaminated water may develop blue-baby syndrome or methemoglobinemia.
• Crop damage: Application at inappropriate times is not only wasteful but can damage crops. Fertilizer burn is defined as leaf scorch resulting from over-fertilization, usually referring to excess nitrogen salts.
- All procured materials must be environmentally friendly and meet host government standards.
- Only seeds and seedlings/planting materials that meet host country sanitary and phytosanitary standards can be used.
Implementing partners must ensure appropriateness for the agro-climatic zone to which seeds are being introduced. No genetically modified organisms (GMOs) are allowable for use.
- Promoting appropriate and quality seed types:
Inappropriate use of seeds could have negative impacts on the environment including introduction of invasive species.
Therefore, it is important to comply with the local regulations, applicable legislations, and planting seed requirements to avoid both known and unknown disturbances in the local environment.
- Climate change should be considered in the selection of seed varieties. Only seeds appropriate to the agro-climatic zones in question should be promoted (in accordance with relevant laws/regulations of Ukraine).
- For any TA or training dealing with pesticides, treated seeds and fertilizers, AGRO will utilize the measures presented in the
PERSUAP for Ukraine DCN: 2018-UKR-044 (or subsequent updates) and follow appropriate guidance provided in the
USAID Sectorial Guidelines on Crop Production, Integrated
Pest Management, and Safer Pesticides Use found here:
https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/sector-environmental-guidelines-resources
- The list of active ingredients (AIs) of pesticides to be procured (after PERSUAP amendment) will correspond with the list of AIs recommended/approved by PERSUAP.
Categorical
Exclusion for educational programs, training, seminars, study tours, advisory and consulting assistance, information sharing, activities for connecting partners
Negative
Determination with Conditions for inputs and supplies purchase, and equipment purchase
USAID/Ukraine/AGRO— IEE Amendment 2 7
• Greenhouse gas emissions: Fertilizer mismanagement can also contribute to greenhouse gas emissions as soil microbes produce nitrous oxide, a GHG. However, in under fertilized areas, fertilizer may contribute little to emissions.
• Acidification: Nitrogen fertilizers can contribute to soil acidification. Acid soils have lower availability of trace elements and can affect the development of nitrogen fixing legumes
Pesticides
• Use of pesticides can result in serious health implications to human health and contamination of the environment. There is now overwhelming evidence that pesticides pose a potential risk to humans and other life forms and unwanted side effects to the environment. Pesticide poisoning can cause deaths and chronic diseases. Pesticides can pollute the tissues of virtually every plant and animal life form on the earth and every natural resource including the air, water, soil, and sediment in rivers.
The high-risk groups exposed to pesticides include agricultural farm workers, but pesticides also affect agricultural food consumers and the public that is exposed to pesticides in the environment, for example, through inadequate notification of pesticide application.
• Misapplication of pesticides and fungicides: While organic pesticides may be less dangerous than synthetic pesticides, they are still considered pesticides, and can result in harm to human health and the environment if not used appropriately.
• Impacts on Human Health and Safety: Poorly designed and operated production processes can put workers at risk of exposure to physical and biological hazards
Pesticide use, procurement, and promotion. Any pesticide use, procurement, or promotion in any activities
- Pesticides, treated seeds and fertilizers will be provided only to the agricultural producers trained by the or other authorized bodies (e.g. industry associations, licensed providers, etc.) for pesticides, treated seeds and fertilizers handling and management. AGRO recipients are expected to have relevant purchase, handling, storage, and develop and follow disposal practices. In handling and applying pesticides, treated seeds and fertilizers users will ensure that they use personal protective equipment (such as gloves, masks/respirators, and goggles) to minimize hazards/risk to themselves. It will be strongly recommended to evaluate the precise requested amount of pesticides and fertilizers properly in order to avoid excessive amounts/left-overs generation with further need for their disposal. Unauthorized disposal of these inputs is not allowed.
Use of empty containers/packages for other purposes is not allowed.
- Sites for operation with pesticides, treated seeds and fertilizers
(storage, preparation of solutions, application, empty packages storage) must not be located where potential adverse impacts will occur to threatened or endangered species or their habitats, including protected areas, water bodies and wetlands. Measures will be taken to minimize risks to non-target species and ecosystems (fish, aquatic invertebrates, birds, mammals, and beneficial insects). Use of treated seed as a food for humans or animals must be avoided.
- Occupational Health and Safety. Occupational safety and health of those involved with formulation and distribution of agricultural inputs (pesticides, traded seeds and fertilizers) will be ensured through development of site health and safety plans which adhere to best safety practices and availability of
Personal Protective Equipment (PPE).
- Warnings must be provided to prevent exposure to certain fertilizers and pesticides, which can cause eye and skin irritation and burns or physical damage to the nose, throat, and lungs through inhalation exposure
- AGRO will provide agricultural producers with training on safe pesticide and fertilizers management (including proper waste disposal) in accordance with PERSUAP provisions and
USAID/Ukraine/AGRO— IEE Amendment 2 8
(including support to extension activities) must fully conform to the country-specific and up-to-date
PERSUAP.
Provision of seeds and other agricultural inputs:
• Poor-quality seeds: Use of poor-quality seed can have a negative effect on crop yields and waste agricultural inputs. Seed-borne fungal pathogens can cause crop diseases.
• Introduction of non-native species: Caution must be exercised when introducing non-native seeds.
Introduction of invasive species can lead to substantial adverse impact to the environment, including displacement or destruction of native plants and insects, crop damage, and loss of biodiversity. Unconsidered introduction of crop, mono-cropping, agroforestry and cover crops, hedges, and windbreaks, riparian buffers and other intentionally introduced non-native species new to a given ecological zone present risks that the species will be disruptive or invasive. Introduced exotic species may spread diseases, out-compete native species for resources, become feral, act as predators or pests, or interbreed with native species.
• Pesticide use in seed treatment: Seeds that are pre-treated with pesticides are not considered pest-control products under the US Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). However, risks associated with treated seed are related to exposure. Adverse health and environmental impacts due to exposure may result from using seed for animal feed, food or oil purposes; improperly storing or composting seed; not following minimal planting depth requirements; spilling treated seed; not following required restrictions; and not using necessary personal protective equipment (PPE) when handling treated seed.
• Agricultural Extensification: Increases in the national regulations (e.g., Law of Ukraine “On pesticides and agrochemicals”, DCP 8.8.1.2.001-98 “State sanitary rules.
Transportation, storage and use of pesticides in the national economy”, NPAOP 01.0-1.02-18 “Rules of labor protection in agricultural production”, etc.
- Practice Safer Pesticide Use. Use best practices throughout the entire pesticide life cycle (from sourcing to container disposal) to minimize pesticide use to only necessary circumstances and assure that pesticides are chosen and used in in the manner in which they present as few risks possible to people, other non-target organisms, and the environment.
- Training and Awareness Raising. All activities requiring and supporting inputs must address adverse environmental and human health impacts of these inputs through raising awareness and training of input suppliers, farmers and extension agenda and consumers.
- Animal feed safety and quality will be confirmed by relevant certificates. AGRO will provide consultancy assistance on feed use via qualified contractors. AGRO recipients are expected to have staff zootechnics to provide proper dosing and composition of the feed as well as correct storage to avoid quality loss. If automatic or mechanical systems are used for feed distribution to poultry and animal livestock, equipment should be operated in compliance with operational manual and its technical condition should be checked regularly to avoid malfunctions and personal injury. If feed is provided packed, reuse of packages (e.g., bags) should be considered with suppliers. Waste disposal procedures should be developed and followed.
- Suitable sites for location of livestock and poultry farms should be selected away from sensitive receptors and population centers. Where appropriate, animals should be tied or fenced in.
- Contractors engaged in actions of intensification of livestock production or leading to intensification of livestock production will integrate their actions aimed at improved rangeland management, feed management, and water resources management.
USAID/Ukraine/AGRO— IEE Amendment 2 9 profitability of agriculture via increased access to improved seed varieties can result in increases in land under cultivation, shift cultivation patterns, and/or push subsistence agriculture into more marginal lands. These can have significant adverse impacts related to land degradation, over-abstraction of scarce water resources, and/or degradation of water quality and introduction of non-native species and planting materials. soil health as a result of overuse or misuse of agrochemicals.
Alternative seed and planting materials. Growers may use or purchase poor quality seed and planting materials from uncertified sources. Using low quality seed and planting materials can have a negative effect on crop yield and waste agricultural inputs.
Impacts associated with veterinary pharmaceuticals and vaccines use. Livestock and poultry production may require using veterinary drugs and vaccines against dieses and pesticides for control of external parasites such as ticks, bots, flies, mites, lice, and other livestock pests.
• Medical waste: Veterinary vaccines or treatments techniques or care situations could generate and require disposal of veterinary-medical wastes (e.g.
sharps, afterbirth, sputum and blood samples, gloves and supplies from AI). The improper use, displacement or disposal could affect the quality of the water, public health, and adjacent environment.
• Generation of waste. Impact of direct or indirect support for processing of animal products will depend on the nature of the products and processes.
Generally, the impact of animal product processing such as animal slaughtering, milk or egg production activities have significant impact on the environment is generation of waste and the associated pollution and contamination. Animal processing waste products may occur as wastewater, solid material, volatile compounds, or GHG gases that contribute to climate change.
- Contractors will introduce practices aimed at minimizing
GHG emissions (e.g., improved animal nutrition, manure management, pasture management).
- Ensure the partner consults with a livestock or poultry specialist on breed selection and fodder/nutrition requirements.
Encourage selection based on both current and future profitability
- Activities related to Animal feedings should meet the conditions reflected in Sector Environmental Guideline:
Livestock (2015) | U.S. Agency for International Development
(usaid.gov)
- Veterinary pharmaceuticals and vaccines will be US-manufactured and procured from the trusted and responsible vendors from the USAID-approved sources and
. AGRO and its recipients will request documentation of the manufacturer’s standards and certifications, and will ensure transportation, storage, and application safety. Only recipients with qualified veterinary and/or zootechnical staff who can ensure correct application of medicine will be provided with veterinary pharmaceuticals and vaccines.
- Training related to veterinary vaccines or treatments techniques or care situations for livestock farms are being addressed per the USAID Sector Environmental Guideline:
Livestock (2015) | U.S. Agency for International Development
(usaid.gov) and that veterinary-medical wastes (e.g., sharps, afterbirth, sputum and blood samples, gloves and supplies from
AI) are properly disposed. The training, curricula, supervision must address appropriate management practices concerning the proper handling, use, and disposal of medical waste.
- Waste generated during the pharmaceuticals and vaccines use to be considered as medical waste and should be disposed accordingly: class A medical waste (which was not in contact with biofluids or internal environments of animal patients) is collected and disposed of as domestic waste; class B medical waste (used medical instruments, items contaminated with biological fluids, used injection needles, biological materials and samples, etc.) should be disposed in accordance with the established procedure (separated, disinfected with special
USAID/Ukraine/AGRO— IEE Amendment 2 10
Animal feed, poultry and animal livestock
• Potential spread of poultry diseases and Avian
Influenza.
• Environmental damage: Livestock can damage habitats and reduce biodiversity of wildlife and domestic stock, vegetation, and aquatic and wetland ecosystems.
• Manure from livestock is often discharged or
“leaked” into lakes or streams. When this occurs, the nutrients can cause eutrophication, solids can create sedimentation, and organic material leads to oxygen depletion (BOD) of the water
• Public health concerns: A zoonotic disease is an infectious disease that is transmitted between species from animals to humans. Animal mobility through transhumance could be a factor in the spread of disease if the animals are not vaccinated.
• Consequences of climate change on livestock and poultry production. Changing climatic conditions
(e.g., shifting precipitation patterns, increased temperatures, increased frequency/severity of storms, etc.) may have adverse impacts on the productivity of livestock production. The reduced availability of grazing land due to climate-related land degradation or desertification may contribute to these processes through overgrazing or otherwise reduce land productivity. Additionally, the changing climate conditions may increase the prevalence of parasites and diseases that affect livestock, reduce water availability for livestock, and decrease the amount of quality forage for grazing livestock.
agents, stored in the separate boxes and transferred for disposal and/or recycling to specialized companies). If immediate transferring for disposal is not applicable, category B waste can be stored onsite in hermetic boxes inaccessible for third parties and avoiding contact with environment.
Additional mitigation measures:
Recommended Guidance:
• Refer to the USAID Sector Environmental Guidelines for Crop Production and Dryland Agriculture for guidance on mitigation of environmental impacts associated with the expansion of agricultural activities that generate waste used in biogas production.
• Refer to the USAID Sector Environmental Guideline for Livestock for guidance on mitigation of environmental impacts associated with livestock management of bioenergy projects.
1.17: Interventions that support AGRO’s business relocation and start-up activities to assist agri-food
MSMEs in setting up the operations in new locations and integrating into new value chains to help secure uninterrupted production and supply of food
Activity will include studies, information sharing, consulting assistance and trainings, legal support, technical assistance, relocation support, and equipment purchase
- All procured materials and equipment must be environmentally friendly and meet host government standards
- If applicable, consider ensuring the uninterrupted access/energy independence for relocated facilities using alternative sources of power supply (e.g. solar batteries installation, etc.)
- The IP will prepare an Environmental Review Checklist
(ERC) and Environmental Mitigation and Monitoring Plan
(EMMP) (Annex B) for activities under Negative
Determination with Conditions (NDC). The ERC/EMMP will be completed and approved within the approval process, prior to activities beginning. In lieu of the ERC/EMMP, for small-scale equipment only, the IP may prepare a Small-Scale
Procurement Environmental Review Form (Annex C).
- Environmental education, that includes consideration for sector specific adverse impacts and mitigations, must be included as part of the technical assistance, studies, consulting assistance, and training.
Categorical
Exclusion for educational programs, training, seminars, study tours, advisory and consulting assistance, information sharing
Negative
Determination with Conditions for equipment purchase
Component 3: Better Policy and Enabling Environment for Small and Medium Agricultural Enterprises
3.16: Interventions that support land
- Potential impact on environment and human health depends on the character and location of the planned
- The IP will prepare an Environmental Review Checklist
(ERC) and Environmental Mitigation and Monitoring Plan
Categorical
Exclusion for
USAID/Ukraine/AGRO— IEE Amendment 2 11 decontamination from the war (including coordinating information sharing with humanitarian organizations focused on demining)
Activities will include studies and analysis, consulting assistance and equipment activity. Further analysis of each individual activity is needed to quantify potential impacts on a case-by-case basis
- Direct impacts of sub-awards may result including impacts on land, water, air, and human health:
- Obsolete equipment (e-waste) may negatively impact the environment if is not disposed properly
- Inappropriate melioration technics may lead to flooding/draining and negative impact on soil, ground water, and air quality
- Disregard of protective measures may cause occupational injuries
- Land decontamination activities may present health and safety risks for farmers or workers if clearance has not been obtained from the relevant organization.
(EMMP) (Annex B) for activities under Negative
Determination with Conditions (NDC). The ERC/EMMP will be completed and approved within the approval process, prior to activities beginning. In lieu of the ERC/EMMP, for small-scale equipment only, the IP may prepare a Small-Scale
Procurement Environmental Review Form (Annex C).
- All procured materials and equipment must be environmentally friendly and meet host government standards
Human Health and Safety: Appropriate personal protective equipment (PPE) shall be provided in delivery, handling, and distribution of equipment.
- Calculated water requirements for each site or area and compare against water budget to ensure that water efficient technologies such as drip irrigation or sprinkler irrigation systems are appropriate for each site.
- Mark all irrigation water sources as inappropriate for drinking water consumption and include the topic of associated health risks in awareness raising campaigns for schools and community and training support to water user groups.
studies and analysis, information sharing, and consulting assistance
Negative
Determination with Conditions for equipment
3.17: Interventions that provide support for the by providing advisory services and technical support on the management of melioration systems during and after the martial law
Activities will include studies and analysis
(including mapping), consulting assistance, research, forums, conferences, study tours, information sharing, and equipment purchase
USAID/Ukraine/AGRO— IEE Amendment 2 12
4. Conclusions of the Environmental Review
4.1. Recommended Environmental Determinations
Categorical Exclusions
A categorical exclusion threshold determination is recommended for the following identified activities under
22 CFR 216.2(c)(2):
• A categorical exclusion pursuant to 216.2(c)(2)(i) for education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment
(e.g. construction of facilities) is recommended for activities 1.16, 1.17, 3.15, 3.16, and 3.17 (for non-equipment purchase activities) from the Section 5 tables.
• A categorical exclusion pursuant to 216.2(c)(2)(iii) for analyses, studies, and research is recommended for activities 1.16, 1.17, 3.15, 3.16, and 3.17 (for non-equipment purchase activities) from the Section 5 tables.
• A categorical exclusion pursuant to 216.2(c)(2)(v) for document and information transfers for activities 1.16, 1.17, 3.15, 3.16, and 3.17 (for non-equipment purchase activities) from the Section
5 tables.
Per 22 CFR 216.2(c)(1), neither an IEE nor an EA is required for activities which are determined to fall within one or more of the classes of activities listed in 22 CFR 216.2(c)(2).
Negative Determination with Conditions:
Under 216.3(a)(2)(iii), a negative determination with conditions is recommended for activities 1.16, 1.17, 3.16, and
3.17 from the Section 5 tables. Specific terms and conditions are presented below in Section 5.3.
4.2. Terms and Conditions:
4.2.1. For activity 1.16, the IP shall promote procurement and application of best available technologies
(BAT) for targeted area, promote drought tolerant plant varieties, and provide targeted TA for long term agricultural planning taking into consideration climate models and precipitation changes.
4.2.2. For pesticide-treated seeds, AGRO shall promote best practices to the final users and ensure their capacity to follow appropriate guidance provided in the USAID Sectorial Guidelines on Crop
Production in part of storage, handling, use, and disposal of packages and seed residues/excess
(https://www.usaid.gov/sites/default/files/documents/1865/CropProduction SEG 25Mar2019.pdf)
4.2.3. For activities dealing with pesticides and fertilizers, the IP will comply with provisions of PERSUAP for Ukraine DCN:2018-UKR-044 and subsequent updates. AGRO may commence procurement of pesticides when PERSUAP for Ukraine will be amended correspondingly. If AGRO makes the decision to procure pesticides, the list of their active ingredients (AIs) will correspond with the list of AIs recommended by PERSUAP.
4.2.4. For activities dealing with fertilizers (pesticide-free mineral and organic (animal or plant-based) eligible under ADS 312 Fertilizer Financing Guidance), AGRO will follow appropriate guidance provided in the USAID Sectorial Guidelines on Crop Production
(https://www.usaid.gov/sites/default/files/documents/1865/CropProduction SEG 25Mar2019.pdf)
4.2.5. For activities dealing with veterinary pharmaceuticals and vaccines, the IP will ensure product approvals, transportation, storage, and distribution, as well as capacity of beneficiaries for proper use of medicine (qualified veterinary and/or zootechnical staff, developed procedures) and waste management system operation.
4.2.6. For activity 3.15, if the IP determines that the proposed legislation may impact the environment and/or human health, the IP will encourage the assisted government authorities to integrate
USAID/Ukraine/AGRO— IEE Amendment 2 13 environmental considerations into the proposed legislation in line with the best international (EU compatible) approaches and practices.
4.2.7. For all site-specific activities (with equipment purchase), the IP will screen for potential environmental impacts and design consideration taking into account existing background conditions such as siting, contamination or utility infrastructure needs etc. using the Environmental Review
Checklist and Environmental Mitigation and Monitoring Plan (ERC/EMMP) (see Annex B). For small-scale equipment purchase only, the Small-Scale Procurement Environmental Review Form
(Annex C) will be completed. Each site specific EMMP shall be tailored to the work to be undertaken.
4.2.8. For each site-specific activity (non-small-scale equipment), the Certification of No Adverse or
Significant Effects on the Environment (Annex 1 of the ERC/EMMP) shall be signed by the IP, AOR, and Mission Environmental Officer (MEO). E&E Bureau Environmental Officer (BEO) concurrence is not required per Memo to File DCN: 2020-UKR-042.
4.2.9. After the IP has finalized its (non-small-scale equipment) activities at a specific site, the IP shall sign a Record of Compliance with the EMMP (see Annex 2 of the ERC/EMMP) certifying that the organization met all applicable EMMP conditions and submit it to the AOR. The AOR shall keep the original for the project files and provide a copy to the MEO and BEO.
4.2.10. The ERC/EMMP or Small-Scale Procurement Environmental Review Form will be completed and approved within the stated approval process, prior to activities beginning.
4.2.11. The requirement for ERC/EMMPs or Small-Scale Procurement Environmental Review Form shall be captured in annual work plans, and therefore budgeted for and reviewed for adequacy at least annually.
4.3. USAID Monitoring and Reporting
4.3.1. The AOR, with the support of the MEO, is responsible for monitoring compliance of activities by means of desktop reviews and site visits.
4.3.2. If at any time the project is found to be out of compliance with the IEE and its amendments, the AOR or MEO shall immediately notify the BEO.
4.3.3. A summary report of Mission’s compliance relative to this IEE amendment shall be sent to the BEO on an annual basis, normally in connection with preparation of the Mission’s annual environmental compliance report required under ADS 203.3.8.5 and 204.3.3.
4.3.4. The BEO or his/her designated representative may conduct site visits or request additional information for compliance monitoring purposes to ensure compliance with this IEE, as necessary.
4.4. Implementing Partner (IP) Monitoring and Reporting
4.4.1. If an individual activity is found to pose significant adverse environmental effects that have not been identified and addressed in this IEE Amendment that were subsequently approved for the project, a an Amendment shall be prepared to include environmental impacts and terms and conditions for such activities.
4.4.2. If an individual activity is found to pose significant adverse environmental effects not identified and addressed through the ERC/EMMP process, they shall update the EMMP(s) to include environmental safeguards for such effects.
4.4.3. IP shall report on environmental compliance requirements as part of their routine project reporting to USAID.
USAID/Ukraine/AGRO— IEE Amendment 2 14
5. Mandatory Inclusion of Requirements in Solicitations, Awards, Budgets and Workplans
5.1. Appropriate environmental compliance language, including limitations defined in Section 7, shall be incorporated into solicitations and awards for this activity and projects budgets shall provide for adequate funding and human resources to comply with requirements of this IEE
Amendment.
5.2. Solicitations shall include Statements of Work with task(s) for meeting environmental compliance requirements and appropriate evaluation criteria.
5.3. Environmental mitigation and monitoring requirements, when available, shall also be included in solicitations and awards.
5.4. The IP shall incorporate conditions set forth in this IEE amendment into their annual work plans.
5.5. The IP shall ensure annual work plans do not prescribe activities that are defined as limitations, as defined in Section 7.
5.6. The USAID Mission will include an indicator for environmental compliance as part of the project’s performance monitoring plan. [If an IEE has a threshold determination of negative determination with conditions, then a possible indictor is if the IP did the ERC/EMMP.]
6. Limitations of this IEE:
This IEE does not cover activities (and therefore should changes in scope implicate any of the issues/activities listed below, a BEO-approved amendment shall be required), that:
6.1. Normally have a significant effect on the environment under §216.2(d)(1) [See http://www.usaid.gov/our_work/environment/compliance/regulations.html]
6.2. Support project preparation, project feasibility studies, engineering design for activities listed in
§216.2(d)(1);
6.3. Affect endangered species;
6.4. Result in wetland or biodiversity degradation or loss;
6.5. Support extractive industries (e.g. mining and quarrying);
6.6. Promote timber harvesting;
6.7. Provide support for regulatory permitting;
6.8. Result in privatization of industrial or infrastructure facilities;
6.9. Lead to new construction of buildings or other structures;
6.10. Until PERSUAP for Ukraine is amended/updated, assist the procurement (including payment in kind, donations, guarantees of credit) or use (including handling, transport, fuel for transport, storage, mixing, loading, application, cleanup of spray equipment, and disposal) of pesticides or activities involving…
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