Attachment J.10 IEE_ TIF .pdf

ME 20-11

INITIAL ENVIRONMENTAL EXAMINATION (IEE)

Trade and Investment Facilitation (TIF) activity

PROGRAM/ACTIVITY DATA:

Country Code-SO: 268-001 Foreign Assistance Objective: Economic Growth Country or Region: Lebanon Activity Name: Trade and Investment Facilitation (TIF)

Funding Begin: 10/01/2020 Funding End: 09/30/2025 LOP Amount: $75,000,000 Sub-Activity Amount:

IEE Prepared by: Georges Frenn, Senior Economic Growth Specialist Date: 09/18/2019

IEE Amendment (Y/N): N

If “Yes,” Number @ Date of Original IEE:

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

air _✔_ water_✔_ land_✔_ biodiversity _✔_ human health _✔_ other _____ none _____

Environmental Action(s) Recommended: (Check all that apply) Categorical Exclusion: ☒ Deferral: ☐

Positive Determination: ☒ Negative Determination with Conditions: ☒

Exemption: ☐

BACKGROUND

USAID/Lebanon will implement a new activity entitled Trade and Investment Facilitation (TIF). TIF is planned to start on October 01, 2020 with a 3-year base period and two additional option periods of 1-year each, ending on September 30, 2025. The activity’s LOP budget is estimated to be $75,000,000.

TIF will facilitate the export of Lebanese goods and services to generate foreign exchange through investments that simultaneously promote job creation, income generation, and improved livelihoods throughout the country. The activity will achieve this through an approach based on USAID’s Private Sector Engagement Policy. Support for reform of the enabling environment, with Lebanese institutions in the lead, will also be provided where opportunities arise. TIF will apply a market led approach that applies USAID best practices in order to identify opportunities to catalyze growth in key Lebanese economic sectors, which will include tourism. TIF will also select and invest in one or more other productive sectors including industry, services, information technology, knowledge economy sectors, or other sectors that offer demonstrated growth and development potential yet face specific identified constraints to unlocking that potential.

Under TIF, USAID will partner with multiple stakeholders within the private sector such as small and medium enterprises (SMEs), startup enterprises, larger international firms, non-governmental organizations (NGOs), chambers of commerce, and private sector business associations, among others. TIF will look to partner with multilateral donors and potentially the new US Development Finance Corporation (DFC). The activity will also seek to partner with government Ministries and other public institutions, where appropriate and as clear opportunities arise, to address constraints to business growth, operations, and investment.

Partnerships will leverage resources and expertise, including in-kind and human resource contributions.

SUMMARY OF FINDINGS

TIF will have the below objectives:

1. Increased Exports of Lebanese Goods and Services

2. Increased Domestic Investment

3. Improved Business and Investment Enabling Environment

These objectives will be achieved through a combination of technical assistance and co-investment grants with key stakeholders to increase access to markets, exports of goods and services and investment.

USAID assistance under TIF is expected to include one, more, or all of the following types of activities:

1) Assessments, desk reviews, and market research that will result in technical assistance and partnership programs that will address the needs of the beneficiaries;

2) Technical assistance and training to various actors in different sectors;

3) Partnerships may include grants that will create trade hubs to increase the competitiveness of specific Lebanese goods and services for export, facilitate increased U.S., foreign, and national investment in Lebanon, create linkages among companies, and strengthen local institutions. The grants might include upgrades of existing facilities and the introduction of new technologies, including the provision of equipment as well as management systems;

4) Knowledge transfer and learning exchange through impact assessments, case studies, cost benefit analyses, as well as exchange trips between local stakeholders to learn about the interventions conducted by the activity.

Table 1 lists activities covered in this IEE as well as their recommended threshold decisions.

Table 1: Proposed program activities and recommended threshold decisions

No Activities Effect on Natural or Physical Environment

Determination and Reg. 216 actions required

I All activity actions that don’t have an effect on the natural or physical environment.

This includes:

- Performance of desk reviews and market analyses, coordinate with other USAID projects and other donors, and perform assessments to be able to determine and identify the assistance and interventions.

- Developing the technical assistance program that will include technical experts and sub-contractors who will provide this assistance to beneficiaries.

- Implementing the technical assistance program through provision of technical trainings and business development services to targeted beneficiaries.

- Identifying potential partners in various sub-sectors with whom the activity will

No effect

Categorical Exclusion, no actions required, per 22 CFR

216.2 (c)(2)(iii) as “analysis, studies, academic or research workshops and meetings”, 22 CFR

216.2 (c)(2)(v) “document and information transfers” and 22 CFR

216.2 (c)(2)(i) as “education, technical assistance, or training programs”.

partner to increase exports and enhance investment.

- Collecting and analyzing data for indicators reporting under the Activity’s Monitoring, Evaluation and Learning (MEL) plan.

- Producing case studies, impact assessments, success stories, fact sheets, videos and other type of relevant materials for both outreach and learning purposes.

- Organizing public events to share the acquired knowledge and to achieve the desired visibility under the activity.

II For activities and procurement of services and commodities that normally do not have a significant effect on the environment, such as, for example:

- Rehabilitation of facilities that will be identified during the inception phase of TIF;

- Procurement of equipment and machinery, technologies, materials, computers, electronics, and services that may have a potential for hazardous environmental impact;

- All other actions having a similar effect on the environment.

Potential for a significant adverse effect of one or more activities

Negative Determination with Conditions

An Environmental Review and Assessment Checklist (ERAC) will be prepared to identify environmental effects for each activity and approved by the Contracting Officer Representative (COR) and the Mission Environmental Officer (MEO), with copies provided to the REA and BEO. Based on the findings of the ERAC and the significance of potential environmental and social impacts, an Environmental Mitigation and Monitoring Plan (EMMP) or an Environmental Assessment (EA) or Environmental Impact Statement (EIS) will be developed and approved by the MEO and the Bureau Environmental Officer for the Middle East (BEO/ME) as per the detailed guidance below.

a) Recommended Action: Categorical Exclusion (approximately 40% of all funding).

Pursuant to 22 CFR 216.2(c)(3), the originator of the activities under Section I of table 1 has determined that TIF interventions focusing on technical assistance and training, and other similar types of environmentally neutral actions, 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 interventions are fully within the following classes of actions:

● 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)];

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

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

● 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 (approximately 30% of all funding) for procurement activities under Section II of Table 1 that follow accepted USAID best practices, approved engineering methods, and standard instructions to avoid potential environmental issues. This includes procurement and disposal of equipment and machinery, technologies, materials, computers and other electric and electronic equipment and services; and procurement and disposal of commodities. The implementer should provide evidence that equipment, commodities, and materials procured with USAID assistance are used and disposed of in a safe and appropriate manner in accordance with all applicable national and international environmental laws .

For other activities under Section II of Table 1 that have a potential for an adverse impact on the natural or physical environment (approximately 30% of all funding), the originator of the action has determined that pursuant to 22 CFR 216.2(d), an Environmental Assessment (EA) or Environmental Impact Statement (EIS), as appropriate, will be required Possible activities envisioned under this activity that could be included in this category include, but are not limited to, upgrading production techniques and quality control systems of businesses in agriculture, industry, health, tourism, technology, or other related sectors, infrastructure improvements including construction and rehabilitation of facilities, and other related activities may have the potential for significant adverse environmental impacts. The implementing partner will prepare an ERAC to identify environmental effects for each activity. The ERAC must be reviewed and approved by the COR and MEO with a copy of the ERAC shared with the REA and BEO for comment.

Based on the findings of the ERAC and the significance of potential environmental and social impacts, the implementing partner(s) has two options: 1) if potentially significant environmental and social impacts are identified, then the implementer(s), based on the approved ERAC, will prepare an EMMP to be approved by the COR and MEO; or 2) if potentially severally significant environmental and social impacts are identified by the ERAC, then the implementer(s): shall conduct public consultations and prepare an EA or EIS to be approved by the Middle East BEO.

Implementing Partner (IP) Procedures:

In addition to the Environmental Review and Assessment Checklist (ERAC) (Attachment 1), the Implementing Partner will employ the following processes for all relevant activities:

Each activity should be conducted in a manner consistent with good design and implementation practices described in USAID global Sector Environmental Guidelines.

● The Implementing Partner(s) must include environmental compliance considerations into all aspects of the activity implementation and will promote and train local counterparts on environmental requirements and standards across all of the activity’s interventions. Such proposed interventions will be incorporated into annual work plans, and results will be reported in annual reports.

● 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 closely adhered to during implementation of all the activities and requisite documentation will be accomplished and maintained by the implementer. Implementing Partner(s) will ensure compliance by its staff, subcontractors, and sub-grantees with USAID environmental regulations, policies, procedures and accepted best practices, as well as compliance with applicable international environmental obligations of Lebanon.

● The Implementing Partner(s) shall also ensure that the best environmental management practices for construction, excavation, dust control, and noise control are adopted; that any solid wastes generated from activities are collected and transferred to appropriate waste management facilities; and that any wastewater generated from activities is properly disposed in community sewage networks and leading to available sewage treatment plants.

● Environmental conditions in this IEE must be incorporated into the award performance criteria for all partners and implementers, including subcontractors and subgrantees.

Climate Risk Management (CRM):

Per ADS 201, a climate risk screening performed by the mission has determined that TIF interventions have a low risk. Climate factors such as higher temperatures, reduced water availability and drought will be an integral part of gaps identification and implementation of the adequate interventions to fill these gaps in the agro-food processing, industrial and tourism sectors. Per the attached climate risk matrix, TIF will explore new opportunities and next steps to address sector challenges when relevant including the most prominent climate change conditions.

Resource Allocation, Training and Reporting requirements:

The award with the implementing partner will include a requirement to follow all recommendations of this IEE. The Implementing partner 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.

The Implementing Partner(s) must comply with the following documentation and reporting requirements associated with the environmental compliance:

● Annual Work Plans must include a section describing all planned activities with any associated potential environmental impacts and risks climate associated risks. Where applicable the EMMP and/or Climate Risk Management Plan shall be included.

● Progress reports and the Final Report will have a section that summarizes the activity’s interventions related to environmental compliance measures and describing environmental assessments and mitigation measures implemented under TIF’s interventions.

● Where applicable, observations about status and results of mitigation measures from the EMMP and climate risk management plan shall be included in all site visit reports, to thoroughly and accurately document that approved mitigation procedures were followed throughout implementation of the subject work. All such reports and documentation must be submitted to the Contracting Officer Representative (COR) and Mission Environmental Officer (MEO). The final report submitted by the Implementing Partner(s) to USAID at the completion of each activity shall include the final results of all environmental mitigation measures applied to the activity and/or documented in the EMMP..

Limitations of the IEE:

This assistance does not cover activities involving:

1. Assistance, procurement or use of genetically modified organisms (GMOs) will require preparation of biosafety assessment review in accordance with ADS 211.3) in an amendment to the IEE approved by Asia

BEO.

2. DCA or GDA programs.

3. Procurement or use of Asbestos Containing Materials (ACM) (i.e. piping, roofing, etc), Polychlorinated Biphenyl’s (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

4. Provision of equipment and training on the safe and sound use of agro-chemicals or pesticides, and the purchase of any agro-chemicals or pesticides unless there is an approved PERSUAP in place that is approved by the BEO/ME.

Revisions:

Pursuant to 22 CFR216.3 (a)(9), if new information becomes available which indicates that activities to be funded by the Program might be “major” and the Program’s effect “significant,” the threshold decisions for those activities listed above with Negative Determination will be reviewed and revised by the originator of the project and submitted to the BEO for approval and, if appropriate, an Environmental Assessment will be prepared.

APPROVAL OF RECOMMENDED ENVIRONMENTAL ACTIONS:

CLEARANCE:

Economic Growth Director USAID/Lebanon Cleared 12-13-20

Stephen Morin Date

Mission Environmental Officer USAID/Lebanon Cleared 12-12-20

Sana Saliba Date

Regional Environmental Advisor USAID/MERP Cleared 1-22-20

Christopher Frey Date

Program Office USAID/Lebanon Cleared 1-24-20

Patrick Goodwin Date

APPROVAL:

Mission Director USAID/Lebanon Anne Patterson Date

CONCURRENCE:

Bureau Environmental Date:

Officer Approved: ☐ John Wilson Disapproved: ☐

IEE TIF Lebanon Activity

ATTACHMENTS:

- Climate Risk Management (CRM) Screening Matrix.

- Example Environment Review and Assessment Checklist (ERAC) & Environment Monitoring and Mitigation Plan (EMMP) template.

- Example Environment inspection checklist template.

DISTRIBUTION:

Mission Environmental Officer IEE File

Environmental Review and Assessment Checklist (ERAC) Insert project name

A. Activity/Sub-project Information Activity Title Description One sentence only.

Individual to Contact— Implementing Partner

Name Title Organization Phone Email if available

Location of Activity (Village Name, District, Governorate, Include GPS coordinates if available

Individual to Contact— Community

Name Title Organization Phone Email if available

Start and End Date

Total Cost Total USAID Funding

B. ERAC Preparer Information Name & Title Contact Information

Organization Phone Email if available

C. Description and Components Summary description.

Provide a 1-2 paragraph description of the activity, with focus on issues of environmental relevance, including location. A longer precis of the activity may be attached if necessary for USAID reviewers to understand potential environmental impacts.

Individual components.

List the individual components of the activity, with brief description where not self-explanatory.

Component Description 1.

2.

3.

4.

D. Screening Screen the entire activity, including all components, against the checklist that follows. Answer “Y” (Yes), “N” (No) or Maybe (M) for each potential concern or impactful project attribute. A "Y" response does not necessarily indicate a significant effect, but rather an issue that requires focused consideration.

CHECKLIST FOR ENVIRONMENTAL CONSEQUENCES: Enter Yes (Y), No (N) or Maybe (M) for each

1. Earth Resources

a. grading, trenching, or excavation >1.0 hectare

b. geologic hazards (faults, landslides, liquefaction, un-engineered fill, etc.)

c. contaminated soils or ground water on the site

d. offsite overburden/waste disposal or borrow pits required >1,0 ton

e. loss of high-quality farmlands >10 hectares

2. Agricultural and Agrochemical

a. impacts of inputs such as seeds and fertilizers

b. impact of production process on human health and environment

c. other adverse impacts

3. Industries

a. impacts of run-off and run-on water

b. impact of farming such as intensification or extensification

c. impact of other factors

4. Air Quality

a. substantial increase in onsite air pollutant emissions (construction/operation)

b. violation of applicable air pollutant emissions or ambient concentration standards

c. substantial increase in vehicle traffic during construction or operation

d. Demolition or blasting for construction

e. substantial increase in odor during construction or operation

f. substantial alteration of microclimate

5. Water Resources and Quality

a. river, stream or lake onsite or within 30 meters of construction

b. withdrawals from or discharges to surface or ground water

c. excavation or placing of fill, removing gravel from, a river, stream or lake

d. onsite storage of liquid fuels or hazardous materials in bulk quantities

6. Cultural Resources

a. prehistoric, historic, or paleontological resources within 30 meters of construction

b. site/facility with unique cultural or ethnic values

7. Biological Resources

a. vegetation removal or construction in wetlands or riparian areas > 1.0 hectare

b. use of pesticides/rodenticides, insecticides, or herbicides > 1.0 hectare

c. Construction in or adjacent to a designated wildlife refuge

8. Planning and Land Use

a. potential conflict with adjacent land uses

b. non-compliance with existing codes, plans, permits or design factors

c. construction in national park or designated recreational area

d. create substantially annoying source of light or glare

e. relocation of >10 individuals for +6 months

f. interrupt necessary utility or municipal service > 10 individuals for +6 months

g. substantial loss of inefficient use of mineral or non-renewable resources

h. increase existing noise levels >5 decibels for +3 months

9. Traffic, Transportation and Circulation

a. increase vehicle trips >20% or cause substantial congestion

b. design features cause or contribute to safety hazards

c. inadequate access or emergency access for anticipated volume of people or traffic

10. Hazards

a. substantially increase risk of fire, explosion, or hazardous chemical release

b. bulk quantities of hazardous materials or fuels stored on site +3 months

c. create or substantially contribute to human health hazard

11. Other Issues (to be used for categories not captured under1 through 10 above)

a. Substantial adverse impact

b. Adverse impact

c. Minimal impact

E. Explanation of Potential Adverse Environmental Impacts with Mitigation and Monitoring Measures (Impact Evaluation + EMMP) In the left column of the table below, explain each “Y” or “M” response in the checklist above, describing potential adverse impacts.

In the middle column, set out mitigation measures to address this issue, differentiating by construction and operation phases as necessary and designating responsible parties.

In the right column, specify how monitoring will be carried out.

If the checklist has no “Y” or “M” responses, skip this section and section F, and proceed to Section G .

NOTE: If an impact is identified as potentially significant, and cannot be made non-significant with basic, straightforward mitigation measures, consult the A/COR and MEO.

The activity is likely to require design changes, or more stringent environmental review will be required.

Issue (from checklist above) & discussion of impacts Mitigation measures

(with responsible party) Monitoring (means/indicator, frequency & responsible party)

(add rows as necessary)

*Any “No” recorded represents the potential breach of regulation or improvement needed and details of nonconformity (NC) shall be recorded in the Remarks.

* Report NC in the following forms. Each NC should make reference into the checklist as coded. The responsible personnel shall identify the root cause of NC and adopt appropriate corrective and preventive actions (CPA) for mitigation. Confirmation of the effectiveness of the CPA shall be verified by Project Manager within an agreed time.

F. Describe how the Project will Assure that Activity-level Mitigation and Monitoring Specified in Section E will be Implemented and Assured

G. Certification. :

I, the undersigned, certify that:

1. The information on this form is correct and complete.

2. Implementation of these activities will not go forward until specific approval is received from the

C/AOR.

3. All mitigation and monitoring measures specified above will be implemented in their entirety, and that staff charged with this implementation will have the authority, capacity, resources and knowledge for successful implementation.

Signature

Date

Print name

Title

BELOW THIS LINE FOR USAID USE ONLY

Review results. Check the box that applies.

All of the following are true. Therefore, the activity may proceed as specified:

● assuming full implementation of all specified mitigation and monitoring measures, the activity has no foreseeable significant adverse impacts; and

● these mitigation and monitoring measures are straightforward and within the reasonable technical capability of the partner; and

● the activity is within the scope of the project’s 22 CFR 216 documentation.

One or more of the following is true. Therefore, the activity may NOT proceed as currently specified:

● the activity is outside the scope of its parent 22 CFR 216 documentation; and/or

● significant adverse impacts remain reasonably possible, even with implementation of all specified mitigation and monitoring measures; and/or

● the mitigation measures are not straightforward and/or are beyond the reasonable technical capability of the partner.

Comments:

*Any “No” recorded represents the potential breach of regulation or improvement needed and details of nonconformity (NC) shall be recorded in the Remarks.

* Report NC in the following forms. Each NC should make reference into the checklist as coded. The responsible personnel shall identify the root cause of NC and adopt appropriate corrective and preventive actions (CPA) for mitigation. Confirmation of the effectiveness of the CPA shall be verified by Project

Record of review (signature indicates concurrence with the above review result)

C/AOR*

(print name) (signature) (date)

USAID/Lebanon MEO*

Regional Env. Advisor (REA)**

*required **optional, except when specified

*Any “No” recorded represents the potential breach of regulation or improvement needed and details of nonconformity (NC) shall be recorded in the Remarks.

* Report NC in the following forms. Each NC should make reference into the checklist as coded. The responsible personnel shall identify the root cause of NC and adopt appropriate corrective and preventive actions (CPA) for mitigation. Confirmation of the effectiveness of the CPA shall be verified by Project

Environmental Site Inspection Checklist (Specify Installation _ Construction_ Operation)

Project Name:

Project Location :

Required Inspection and Frequency

Status during inspection:

Inspection Date :

Inspection Time:

Weather: __________________________________________________________

Inspected by: ___________________________________________________________

Inspection Items

Implemented

N/A Responsibility

Observations, Remarks, and Non-conformity

(i.e. specify location, good practices, problems observed if any, possible cause of nonconformity, proposed corrective/preventative actions, who is responsible for them, who is the entity that you talked with and his/her contact info, the deadline given for addressing the corrective measures, Picture ID on site)

Yes No*