RFP 72062321R00003 LLS - Attachment J.9 IEE.pdf

INITIAL ENVIRONMENTAL

EXAMINATION

PROJECT/ACTIVITY DATA

Project/Activity Name: Locally Legitimate Stabilization (LLS) Geographic Location(s) (Country/Region): Somalia Amendment (Yes/No), if Yes indicate # (1, 2...): No Implementation Start/End Date (FY or M/D/Y): May 21, 2021-May 20, 2026 If Amended, specify New End Date:

Solicitation/Contract/Award Number(s): TBD Implementing Partner(s): TBD Bureau Tracking ID: Somalia LLS IEE Tracking ID of Related RCE/IEE (if any): Somalia_TO1_Inclusive Governance-2018-02-28 Tracking ID of Other, Related Analyses:

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

USAID Somalia

Other Affected Operating Unit(s):

Lead BEO Bureau: AFR/SD Funding Account(s) (if available):

Original Funding Amount: $50 million If Amended, specify funding amount:

If Amended, specify new funding total:

Prepared by: Zahra Mohamed-PMS Stabilization and David

Kinyua, REA, East Africa Date Prepared: August 18 2020

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: Environmental Examination

Deferral

Environmental Determination(s): Categorical Exclusion(s) Negative Positive Deferred (per 22 CFR 216.3(a)(7)(iv)

IEE Expiration Date (if applicable): May 20, 2026 Additional Analyses/Reporting Required: CRM, EMMP & ERF Climate Risks Identified (#): Low _19__ Moderate ___#___ High ___5___ Climate Risks Addressed (#): Low _19__ Moderate ___#___ High ___5___

THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS

PROJECT/ACTIVITY SUMMARY

The goal of Locally Legitimate Stabilization (LLS) is to increase vulnerable communities' resilience to exploitation by Violent Extremist Organizations (VEOs) like Al Shabaab (AS), thus reducing the physical and political space for negative actors to hinder Somalia's development. LLS stabilization activities will build the foundation of inclusive political systems at the local level, working to establish reliable and legitimate local governance, strengthen social cohesion, and address grievances that drive conflict. These efforts will increase confidence in governance and reduce grievances that violent extremist organizations like AS are able to leverage to gain support.

ENVIRONMENTAL DETERMINATIONS

Upon approval of this document, the negative determination become affirmed, per Agency regulations (22

CFR 216).

TABLE 1: ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion Citation (if applicable)

Negative Determination

Positive Determination1

Deferral2

Project/Activity 1: Early recovery

Sub-activity 1.1: Pre-liberation community dialogue

Sub-activity 1.2: Post-liberation dialogue/ neighborhood meetings

Sub-activity 1.3 Social reconciliation to promote community cohesion

Sub-activity 1.4 Improve access to services through initial investments in public goods (i.e district administration offices)

Project/Activity 2: Increasing Connectivity between citizens and local governance Sub-activity 2.1 Conduct public awareness and engage the community members in participatory decision making and inclusion.

2.2 Support participatory

planning process in targeted communities, including citizen-led implementation of small-scale ‘peace dividend’ activities.

1 Positive Determinations require preparation of a Scoping Statement and Environmental Assessment.

2 Deferrals must be cleared through an Amendment to this IEE prior to implementation of any deferred activities.

CLIMATE RISK MANAGEMENT

BEO SPECIFIED CONDITIONS OF APPROVAL

1. Reporting Conditions:

While this IEE is an essential part of the Agency’s Environmental Procedures documentation, other subsidiary documents are also critical to ensuring that the conditions of this IEE are implemented and the potential for environmental impact is appropriately avoided or minimized. Those subsidiary documents need to be readily available for review by the Agency’s Environmental Officers/Advisors who are charged with facilitation and oversight of the Bureau’s Environmental Procedures implementation – the Mission Environmental Advisor (MEO), the Regional Environmental Advisor (REA), and the Bureau Environmental Officer (BEO). Therefore, the Activity managers/AORs/CORs are expected to store the following subsidiary documents in a common, clearly-labeled and organized folder where the above-referenced Environmental Officers/Advisors can access them:

• Environmental Mitigation and Monitoring Plans/Reports (EMMPs/EMMRs) that are written to implement the findings of this IEE;

• Sub-project Environmental Review Forms (ERF) and Environmental Review Reports (ERRs) used to assess and report on the environmental screening of activities whose details were not known at the time the IEE was prepared, per this IEE’s guidance.

It is requested/recommended that these documents should be uploaded into the appropriate sub-folder(s) of this Google Drive folder: https://drive.google.com/drive/folders/1q7HGMzgopJ- MuKxkQEJ4GSPp9R7Qzv-5?usp=sharing. This will facilitate access by all parties who need these documents, including the Mission Environmental Officer and the AOR/COR. Further, this will allow the REA and the BEO Team to spot-check and review these documents to confirm that the mitigations appropriate and are responsive to the expectations of the IEE.

IMPLEMENTATION

In accordance with 22 CFR 216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Sections 3, 4, and 5 of the IEE and any BEO Specified Conditions of Approval.

https://drive.google.com/drive/folders/1q7HGMzgopJ-MuKxkQEJ4GSPp9R7Qzv-5?usp=sharing

USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY NAME: Locally Legitimate Stabilization (LLS) Bureau Tracking ID:

Approval: Cleared electronically 10/12/2020 Patrick Diskin, Mission Director Date

Clearance: Cleared 08/21/2020 Dan Hicks, Acting DSG Office Director, Date

Clearance: Cleared 08/25/2020 Sam Sager, COR Date

Clearance: Cleared electronically 08/27/2020 David Kinyua, Regional Environmental Advisor Date

Clearance: Cleared electronically 08/25/2020 Kelly Mack, Regional Legal Officer Date

Clearance: Cleared by email 09/01/2020 Lily Beshawred, Supervisory Program Officer Date

Clearance: Cleared 09/25/2020 Brian Frantz, Deputy Mission Director Date

Clearance: Cleared by email 10/21/2020 Colin Quinn, Climate Integration Lead Date

Concurrence: 11/04/2020 Brian Hirsch, Bureau Environmental Officer Date

DISTRIBUTION:

DSG, OAA, PROGRAM OFFICEINITIAL ENVIRONMENTAL EXAMINATION

Cleared by email

INITIAL ENVIRONMENTAL

EXAMINATION

CONTENTS

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE OF THE IEE 6

1.2 PROJECT/ACTIVITY OVERVIEW 6

1.3 PROJECT/ACTIVITY DESCRIPTION 6

2.0 BASELINE ENVIRONMENTAL INFORMATION

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL,

CLIMATE, SOCIAL, Threatened and ENDANGERED species) 8

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL

STANDARDS (E.G. WHO), ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND

REGULATIONS 9

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS

APPROPRIATE) 10

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

4.0 ENVIRONMENTAL DETERMINATIONS

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS 13

4.2 CLIMATE RISK MANAGEMENT 13

5.0 CONDITIONS AND MITIGATION MEASURES

5.1 CONDITIONS 15

5.2 AGENCY CONDITIONS 16

5.3 MITIGATION MEASURES 16

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION

7.0 REVISIONS

ATTACHMENTS:

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE OF THE IEE

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID intervention described herein and recommend determinations and, as appropriate, conditions, for these activities. Upon approval, these determinations become affirmed, and specified conditions become mandatory obligations of implementation. This IEE also documents the results of the Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

This IEE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound design and implementation. Potential environmental impacts should be addressed through formal environmental mitigation and monitoring plans (EMMPs) and/or Environmental Assessments (EAs), if needed.

1.2 PROJECT/ACTIVITY OVERVIEW

Locally Legitimate Stabilization (LLS) stabilizes select regions of Somalia by increasing confidence in local governance to the extent that Somalis look to and support non-extremist formal and informal governance structures. USAID defines legitimate local governance as local government systems that 1) are inclusive, responsive, and accountable to all groups, including minority and marginalized populations; and 2) provide basic security necessary to prevent future VEO incursions and allow the return of normal social and economic activities. LLS is the third iteration of mission-managed stabilization programming, following the original TIS (implemented by IOM and DAI), which operated from 2010-2015 and TIS+ (2015-2021).

LLS places building the legitimacy of governance institutions and processes at the center of its stabilization approach. Somalia’s governance institutions have suffered from a lack of local legitimacy that has undermined their ability to secure territory and mobilize communities against Al Shabaab. This lack of legitimacy stems from an inability to provide basic services, exclusionary governance processes, and persistent clan conflict. The legitimacy deficit has meant that local governance continues to find it challenging to implement policies and often faces violent opposition to their presence.

1.3 PROJECT/ACTIVITY DESCRIPTION

The Project activities are summarized in the following table:

Objective 1: Trust in Governance Increased LLS will create platforms and opportunities for increased citizen engagement in formal government institutions, such as local and district administrations and security structures, as well as informal or private decision-making processes such as peace committees, clan elders, and other decision-making forms which control access to important resources.

Objective 2: Increased Social Cohesion Within and Across Communities LLS will create the conditions that will enable local reconciliation efforts to move forward peacefully by increasing the social cohesion within and across the communities it works in. LLS can better prepare communities to deal with the tensions that arise when reconciliation processes over these sensitive issues proceed.

Small Grant Activities (SGA) are the primary implementation mechanism for LLS. Best practices in stabilization programming highlight the effectiveness of timely, targeted small grants. The majority of small-grant recipients will be local entities, often governmental. Subject to compliance with ADS 302, the grantees under the SGA can include a wide range of governmental and nongovernmental organizations, including local faith-based groups; youth associations; cooperatives; associations; informal groups; Non- Governmental Organizations (NGOs); local, regional, and national governments; Private Voluntary https://www.usaid.gov/our_work/environment/compliance/22cfr216 https://www.usaid.gov/our_work/environment/compliance/22cfr216 https://www.usaid.gov/ads/policy/200/201mal

Organizations (PVOs); U.S. organizations; student groups; media; international organizations; private sector; and coalitions of these entities.

Infrastructure investment will be appropriately sized to accomplish the stabilization effect, as opposed to capital improvements.

TABLE 2: DEFINED OR ILLUSTRATIVE PROJECTS/ACTIVITIES AND SUB-ACTIVITIES

Project/Activity 1 — Early Recovery Sub-activity 1.1 Pre-liberation community dialogue Sub-activity 1.2 Post liberation dialogue/ neighborhood meetings

Sub-activity 1.3 Social reconciliation to promote community cohesion

Sub-activity 1.4 Improve access to services through initial investments in public goods (i.e district administration offices)

Project/Activity 2 — Increasing Connectivity between citizens and local governance Sub-activity 2.1 Conduct public awareness and engage the community members in participatory decision making and inclusion.

Sub-activity 2.2 Support participatory planning process in targeted communities, including citizen-led implementation of small-scale ‘peace dividend’ activities.

Will this project/activity involve construction3 as defined by ADS 201 and 303? Yes No

3 Construction, as defined by ADS 201 and 303, includes: construction, alteration, or repair (including dredging and excavation) of buildings, structures, or other real property and includes, without limitation, improvements, renovation, alteration and refurbishment. The term includes, without limitation, roads, power plants, buildings, bridges, water treatment facilities, and vertical structures. In the box below, describe any construction planned for this project/activity. Refer to ADS 201maw for required Construction Risk Management procedures.

If yes, describe in the space below:

Yes, the project will likely involve small scale infrastructure activities mainly, rehabilitation of existing structures and solar street light installation.

https://www.usaid.gov/sites/default/files/documents/1865/201maw.pdf

2.0 BASELINE ENVIRONMENTAL INFORMATION

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL,

CLIMATE, SOCIAL, THREATENED AND ENDANGERED SPECIES)

A Swedish International Development Agency (2012) report indicated that the key environmental challenges in Somalia are related to deforestation, land degradation, increasing aridity and overgrazing, water scarcity, waste disposal, climate change and ecosystem services. These challenges have only grown worse since then. The poverty-environment linkages in Somalia are related to: increased conflict and general instability particularly related to further marginalization of vulnerable men and women; lack of secure tenure to land and other natural resources; vulnerability to natural disasters and resilience;

polluted water and waste disposal especially along coastland destructive to health; unreliable access to food and water leading to malnutrition and famine; low ability of particularly female-headed households to accumulate assets including land; and access to forest produce for monetary income. Women and girls are disproportionately at risk due to gender roles and inequalities. Corruption is an issue holding back the development of Somalia and is a dilemma also affecting further environmental degradation or an environmental recovery.

Somalia suffers widespread poverty, low levels of education and skills, and vulnerability to negative coping strategies. With 70 percent of the population in Somalia under the age of 30, increasing youth engagement in productive livelihoods is a major step in helping Somalia on its path to stability and economic recovery (World Bank Report, 2018). The country also faces a significant threat from a recent locust invasion and

COVID-19.

The Somali population is approximately 15 million people, with 2.6 million internally displaced and nearly 2 million Somalis in the diaspora. Somalia’s population growth rate is nearly 3 percent, with little indication of a decline as the average fertility rate is 6.9 children per woman. The population is also very young, with 82 percent under the age of 35, 79 percent under the age of 25, and 62 percent under the age of 17.

Urbanization is quickly intensifying at an annual rate of 4 percent, and Somalis are almost equally split between urban (45 percent) and rural areas (55 percent). Nearly 7 out of 10 Somalis live in poverty, the 6th highest poverty rate in Africa.

These demographic challenges are exacerbated by frequent climatic shocks, which, together with inequality and conflict, proliferate an ongoing humanitarian crisis. Somalia is also grappling with fundamental governance issues such as power sharing between federal government and federal member states, low state capacity, and democratization. Government efforts to build institutional capacity, grow the economy and revenue base, and augment service delivery, occur in a context marked by the continuous influence of violent extremism from Al Shabaab (AS). AS remains a formidable threat and continues to demonstrate the ability to launch deadly strikes against “soft targets” and innocent civilians across Somalia and beyond its borders. Somalia is particularly affected by the current COVID-19 pandemic, through both the immediate impact of the shock as well as its longer term effect on the economy and Somalis’ ability to recover in the coming years.

LLS will prioritize engagement in areas recently recovered from al-Shabaab and areas that remain heavily under the influence of al-Shabaab. Notably different in this CDCS is the geographic narrowing of the Mission’s implementation. Previous experience proves that programming countrywide without synchronization leads to lower-level sectoral results that cannot aggregate into desired high-level development objectives. For those reasons, the Mission has limited development programming to the highlighted geographic region depicted below. This will allow programming complementarity and aggregated impact. LLS operates in the Mission-designated region, with exceptions made to support larger USG, Somali, and international interventions as needed. Specific areas will be determined by USAID after award. However, due to the fluid nature of Somalia, LLS may expand or relocate to other parts of Somalia as conditions or opportunities emerge. Program geographic expansion or relocation may be directed by the USAID Contracting Officer Representative (COR) in consultation with Mission senior management at any time during the contract.

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL

STANDARDS (E.G. WHO), ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS

Somalia is a signatory to the United Nations Framework Convention on Climate Change4. In 2018, the federal government launched a new initiative to meet its obligations under three key international conventions on climate change, biodiversity and desertification which was agreed during the 1992 Earth Summit in Rio de Janeiro. However, the National Environmental Policy which was developed in 2013 that provides a good framework for sustainable management of the country’s natural resources is yet to be enacted.

The country developed its National Biodiversity Strategy and Action Plan in 2015 with the objectives of creating a shared understanding of biodiversity among the stakeholders at the national and regional levels in Somalia and aligning their commitment to biodiversity conservation with the overall Strategic Plan for Biodiversity 2011-20205. Following a decade of intense conflict during the 1990’s, recent years have seen an iteration of encouraging transitions, laying the foundations for a more stable political settlement. The

4 UN 1992 https://treaties.un.org/Pages/ViewDetailsIII.

;[aspx?src=TREATY&mtdsg_no=XXVII-7&chapter=27&Temp=mtdsg3&clang=_en 5 Ullah, Saleem and Gadain, Hussein 2016. National Biodiversity Strategy and Action Plan (NBSAP) of Somalia, FAO-Somalia https://www.cbd.int/doc/world/so/so-nbsap-01-en.pdf https://treaties.un.org/Pages/ViewDetailsIII.aspx?src=TREATY&mtdsg_no=XXVII-7&chapter=27&Temp=mtdsg3&clang=_en https://treaties.un.org/Pages/ViewDetailsIII.;%5baspx?src=TREATY&mtdsg_no=XXVII-7&chapter=27&Temp=mtdsg3&clang=_en https://treaties.un.org/Pages/ViewDetailsIII.;%5baspx?src=TREATY&mtdsg_no=XXVII-7&chapter=27&Temp=mtdsg3&clang=_en https://www.cbd.int/doc/world/so/so-nbsap-01-en.pdf https://www.cbd.int/doc/world/so/so-nbsap-01-en.pdf agreement to adopt a federal system is enshrined in the 2011 Provisional Constitution. Institutional reforms have improved nascent institutions, but they are still far from being optimal.

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS

APPROPRIATE)

At the federal level, the Ministry of Natural Resources drafted a National Environmental Policy in 2013 that covers seven sectors. In addition to the key environmental threats identified by this assessment, the policy also covers marine and mineral resources. The policy also covers cross-sectoral issues that include gender, poverty and climate change. The policy document is yet to be enacted but provides a framework for sustainable management of the country’s natural resources. The real challenge will be in implementing the policy approaches outlined in the document, given the political and resource limitations of the Federal Government. Recent developments include the establishment of the Directorate of Environment and Climate Change under the office of the Prime Minister in 2016 with the support of UNDP. The office acts as the focal point for multilateral environmental agreements (MEAs) and coordinates national level actions with the line ministries in order to assist the country meet its obligations under the MEAs. The Directorate is currently leading a climate adaptation project funded by Global Environment Facility (GEF) through UNDP focusing on sustainable water management and expanded drought and flood early-warning systems6.

Policy and legislation with respect to the environment is weak and usually outdated. Existing policies, and those in development would benefit from environmental input, in terms of assessing their potential impacts on the environment, or how they could better contribute to environmental conservation and livelihood improvement, through the use of MEA While these policies demonstrate progress, the reality is that traditional customary laws, rules and regulations remain the backbone for resolving disputes, including those related to management of local resources. One of the main challenges is to harmonize customary laws with modern laws and policies.

Systems for environmental governance in Somalia exist along two lines: the traditional, communal systems (Xeer) and the government structures that have their roots in the colonial and pre-war legislation.

The line between the two sometimes blurs as postwar structures lean heavily on the Xeer and the clan system of governance. This is very much the case when it comes to natural resources management. The demarcation of land in northern Somalia (Puntland and Somaliland) suggests that approximately 50% of all land is permanent pasture, which is governed by customary law. For Somalia as a whole, 46 to 56% of the country’s land area is permanent pasture. About 14% is classified as forest and approximately 13% is suitable for cultivation. Historically, land has always been a common asset governed by customary law.

The federal government and the governments of Somaliland and Puntland have since developed structures and policies to address the damage caused by unsustainable exploitation of natural resources.

Unfortunately, gaps in reach and capacity have reduced their effectiveness, leaving grassroots natural resource management to individual communities with grave consequences for the resilience of ecosystems and the quality of services they provide to rural communities.

6 GEF 2019: https://www.thegef.org/news/somalia-and-undp-launch-new-10-million-project-climate-adaptation-and-water-access-rural https://www.thegef.org/news/somalia-and-undp-launch-new-10-million-project-climate-adaptation-and-water-access-rural https://www.thegef.org/news/somalia-and-undp-launch-new-10-million-project-climate-adaptation-and-water-access-rural https://www.thegef.org/news/somalia-and-undp-launch-new-10-million-project-climate-adaptation-and-water-access-rural

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

Many of the activities under this project will not have direct adverse environmental impacts. The activities are not likely to involve biophysical interventions. The key focus is governance related activities that will involve capacity building, technical assistance, communication campaigns, research, community dialogues and other activities of similar nature. None of these activities are likely to affect the environment directly. However, there are some specific categories of activities that will have direct bearing on the biophysical environment.

These activities include:

Small scale construction including rehabilitations of existing structures: Confidence in government increased in newly recovered areas, one of the project’s key results, will largely involve the improvement of access to services through initial investments in public goods and availability of government offices where the citizens can access government services.

PROJECT/ACTIVITY 1: TRUST IN GOVERNANCE INCREASED

TABLE 3A. POTENTIAL IMPACTS – PROJECT/ACTIVITY 1

Project/Activity Potential environmental and social impacts Sub-Activity 1.1: Pre-liberation community dialogue

Pre-liberation community dialogue has no adverse effects on the environment.

Sub-activity 1.2: Post- liberation dialogue/ neighborhood meetings.

Post- liberation dialogue/ neighborhood meetings have no adverse effects on the environment.

Sub-activity 1.3: Social reconciliation activities to promote community cohesion.

Social reconciliation activities to promote community cohesion has no adverse effects on the environment.

Sub-activity 1.4: Improve access to services through initial investments in public goods (i.e district administration offices- involving small grants with construction activities)

• Disturbance to existing landscape/habitat: Construction typically necessitates clearing, grading, trenching and other activities that can result in near-complete disturbance to the pre-existing landscape/habitat within the plot. If the plot contains or is adjacent to a permanent or seasonal stream/water body, grading and leveling can disrupt local drainage.

• Sedimentation/fouling of surface waters: Runoff from cleared ground or materials stockpiles during construction can result in sedimentation/fouling of surface waters, particularly if the site is located in close proximity to a stream or water body.

• Stagnant water: Construction may result in standing water on-site, which readily becomes breeding habitat for mosquitoes and other disease vectors; this is of particular concern as malaria is endemic in Somalia.

• Occupational and community health and safety hazards:

The construction process and construction sites present a number of hazards: fall and crush injuries, hazards from hand or power tools and equipment used in construction, and exposure to hazardous substances, such as solvents in paint, cement dust, etc. Failure to provide appropriate sanitation on-site can spread infections and diseases in the community.

• Increased Air and Noise Pollution can result during construction or rehabilitation from the actions of construction equipment and workers.

• Adverse impacts of materials sourcing. Construction requires a set of materials often procured locally: timber, fill, sand and gravel, bricks, etc. Unmanaged extraction of these materials can have adverse effects on the environment. For example, stream bed mining of sand or gravel can increase sedimentation and disturb sensitive ecosystems; purchase of timber from unmanaged or illegal concessions helps drive deforestation. Similarly, the operation of constructed facilities has a well-known set of potential adverse impacts.

• General/institutional facilities and compounds generate a set of waste streams (e.g., gray water, latrine discharge, solid waste). In general, if improperly managed, such wastes can contaminate ground and surface water, create breeding habitat for disease vectors, etc.

PROJECT/ACTIVITY 2: INCREASED SOCIAL COHESION WITHIN AND ACROSS COMMUNITIES

TABLE 3B. POTENTIAL IMPACTS – PROJECT/ACTIVITY 2

Project/Activity Potential environmental and social impacts Sub-Activity 2.1: Conduct public awareness and engage the community members in participatory decision making and inclusion.

No effect on the environment anticipated

Sub-activity 2.2: Support participatory planning process in targeted communities, including citizen-led implementation of small-scale ‘peace dividend’ activities.

Although the small-scale ‘peace divided’ activities are not identified at this point, they are expected to involve biophysical interventions, such as small-scale construction, water development, etc. All biophysical interventions are likely to have moderate impacts on the environment and due consideration will need to be given to design appropriate mitigation measures.

4.0 ENVIRONMENTAL DETERMINATIONS

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS

The following table summarizes the recommended negative determination based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22 CFR 216. Specified conditions, detailed in Section 5, become mandatory obligations of implementation, per ADS 204.

TABLE 4: ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion Citation (if applicable)

Negative Determination

Positive Determination7

Deferral8

Project/Activity 1: Trust in Governance Increased Sub-activity 1.1: Pre-

Sub-activity 1.2: Post liberation/ neighborhood meetings.

Sub-activity 1.3: Social

Sub-activity 1.3: Improve access to services through initial investments in public goods (i.e district administration offices-involving small grants with construction activities?

Project/Activity 2: Increased Social Cohesion Within and Across Communities Project/Activity 2.1: Conduct public awareness and engage the community members in participatory

Project/Activity 2:2 Support participatory planning process in targeted communities, including citizen-led implementation of small-scale ‘peace dividend’ activities.

4.2 CLIMATE RISK MANAGEMENT

This section summarizes the methodology used and findings of the CRM Screening, in accordance with ADS 201mal. The project design team, in consultation with the CIL, considered the potential effect of climate risks/stressors on the sustainability of the project (changing precipitation patterns, rising temperature, floods, droughts, fires, landslides, etc.) in addition to the impact of project activities on the

7 Positive Determinations require preparation of a Scoping Statement and Environmental Assessment.

8 Deferrals must be cleared through an Amendment to this IEE prior to implementation of any deferred activities.

https://www.usaid.gov/ads/policy/200/201mal climate (increased greenhouse gas emissions, land use changes, etc.). See Annex 1 for the compete CRM table.

Climate Change With almost 30 years of armed conflict and droughts and floods, there is a constant, but increasingly acute, humanitarian crisis in Somalia. The climate in Somalia is arid to semi-arid. Livestock and rain-fed agriculture, the main livelihoods and components of the economy, directly depend on the weather and environment. Lack of state control or any other effective form of governance has led to widespread misuse and overuse of natural resources and environmental degradation. The commercial production and export of charcoal resulting in deforestation has intensified, contributing to drought, and is an important part of the war economy, with much of the proceeds going to warlords. The armed conflict can hinder the normal movement of pastoralists and others moving due to drought, as they cannot pass through certain unsafe areas. Studies on the impacts of climate change for the Horn of Africa in general predict that the region will be facing more extreme and frequent droughts and floods. These may include severe droughts interrupted by devastating floods that may occur more frequently and result in large-scale starvation and the death of people and livestock.

It is anticipated that Somalia’s vulnerability to climate change will be intensified by its extremely high dependency on the natural resource base and low Human Development Indicators. The sectors most vulnerable to climate change include water resources, agriculture and food security, animal husbandry, grazing and rangelands, health, marine and coastal resources, biodiversity, and exacerbation of natural disasters. Droughts have long contributed to human migration, cultural separation, population dislocation and the collapse of prehistoric and early historic societies. One-third of the people in Africa live in drought-prone areas and are vulnerable to the impacts of droughts. These impacts are often further exacerbated by health problems, particularly diarrhea, cholera and malaria. Pastoralism, the dominant rural livelihood in Somalia, faces severe constraints in adapting to climate change largely due to increasing land degradation; conflicts over scarce resources, which limit movement and destroy assets that are key for adaptation; limited access to information (including that on weather, climate change, markets, as well as pest and disease outbreaks); limited education, skills and access to financial services and markets required to diversity; inadequate government policies, capacities and coordination;

demographic pressures; and social and gender inequalities and marginalization, which reduce the voice and adaptive capacity of the most vulnerable. Enhancing the adaptive capacity of pastoralists will require community-based and community-led interventions, but will also require tailored support from NGOs, donors, and governments.

The climate change risk management (CRM) screening for LLS shows that the risk to this activity as a result of Climate Change is Low. This activity largely involves policy support, technical assistance, institutional capacity building and strengthening, coordination of policies and security related interventions. The nature of the planned activities minimizes risk from direct adverse climate change impacts. However, some potential activities of the program may involve small scale construction that could be impacted by climate change.

5.0 CONDITIONS AND MITIGATION MEASURES

5.1 CONDITIONS

The environmental determinations in this IEE are contingent upon full implementation of the following general implementation and monitoring requirements, as well as ADS 204 and other relevant requirements.

5.1.1 During Pre-Award:

5.1.1.1 Pre-Award Briefings: As feasible, the design team and/or the cognizant environmental officer(s) (e.g., MEO, REA, BEO) will provide a pre-award briefing for potential offerors on environmental compliance expectations/responsibilities at bidders’ conferences.

5.1.1.2 Solicitations: The design team, in coordination with the CO, will ensure solicitations include environmental compliance requirements and evaluation criteria. The CO will ensure technical and cost proposal requirements include approach, staffing, and budget sufficient for complying with the terms of this IEE.

5.1.1.3 Awards: The COR, in coordination with the CO, will ensure all awards and sub-awards, include environmental compliance requirements.

5.1.2 During Post-Award:

5.1.2.1 Post-Award Briefings: The COR and/or the cognizant environmental officer(s) (e.g., MEO, REA, BEO) will provide post-award briefings for the IP on environmental compliance responsibilities.

5.1.2.3 Workplans and Budgeting: The COR will ensure the IP integrates environmental compliance requirements in work plans and budgets to comply with requirements, including EMMP implementation and monitoring.

5.1.2.4 Staffing: The COR, in coordination with the IP, will ensure all awards have staffing capacity to implement environmental compliance requirements.

5.1.2.5 Records Management: The COR will maintain environmental compliance documents in the official project/activity file and upload records to the designated USAID environmental compliance database system.

5.1.2.6 Host Country Environmental Compliance: The COR will ensure the IP complies with applicable and appropriate host country environmental requirements unless otherwise directed in writing by USAID. However, in the case of a conflict between the host country and USAID requirements, the more stringent shall govern.

5.1.2.7 Work Plan Review: The COR will ensure the IP verifies, at least annually or when activities are added or modified, that activities remain with the scope of the IEE. Activities outside of the scope of the IEE cannot be implemented until the IEE is amended.

5.1.2.8 IEE Amendment: If new activities are introduced or other changes to the scope of this IEE occur, an IEE Amendment will be required.

5.1.2.14 USAID Monitoring Oversight: The COR or designee, with the support of the cognizant environmental officer(s) (e.g., MEO, REA, BEO), will ensure monitoring of compliance with established requirements (e.g., by desktop reviews, site visits, etc.).

5.1.2.16 Environmental Compliance Mitigation and Monitoring Plan: The COR will ensure the IP develops, obtains approval for, and implements Environmental Mitigation and Monitoring Plans (EMMPs) that are responsive to the stipulated environmental compliance requirements.

5.1.2.17 Environmental Compliance Reporting: The COR will ensure the IP includes environmental compliance in regular project/activity reports, using indicators as appropriate; develops and submits the Environmental Mitigation and Monitoring Reports (EMMRs); and completes and submits a Record of Compliance (RoC) describing their implementation of EMMP requirements in conjunction with the final EMMR or at the close of sub activities (as applicable). And where required by Bureaus or Missions, ensure the IP prepares a closeout plan consistent with contract documentation for COR review and approval that outlines responsibilities for end-of-project operation, the transition of other operational responsibilities, and final EMMR with lessons learned.

5.1.2.18 Corrective Action: When noncompliance or unforeseen impacts are identified, IPs notify the COR, place a hold on activities, take corrective action, and report on the effectiveness of corrective actions. The COR initiates the corrective action process and ensures the IP completes and documents their activities. Where required by Bureaus or Missions, ensure Record of Compliance is completed.

5.2 AGENCY CONDITIONS

5.2.1 Sub-award Screening: The COR will ensure the IP uses an adequate environmental screening tool to screen any sub-award applications and to aid in the development of EMMPs.

5.2.2 Programmatic IEEs (PIEE): PIEEs stipulate requirements for additional environmental examination of new or country specific projects/activities. The COR of any project/activity being implemented under a PIEE will ensure appropriate reviews are conducted, typically through a Supplemental IEE, and approved by the cognizant BEO.

5.2.3 Supplemental IEEs (SIEEs): An SIEE will be prepared for any new project/activity being planned which fall under a PIEE. The SIEE will provide more thorough analysis of the planned activities, additional geographic context and baseline conditions as well as specific mitigation and monitoring requirements.

5.2.4 Other Supplemental Analyses: The COR will ensure supplemental environmental analyses that are called for in the IEE are completed and documented.

5.2.5 Resolution of Deferrals: If a deferral of the environmental threshold determination was issued, the COR will ensure that the appropriate 22CFR216 environmental analysis and documentation is completed and approved by the BEO before the subject activities are implemented.

5.2.6 Positive Determination: If a Positive Determination threshold determination was made, the COR will ensure a Scoping Statement, and if required an Environmental Assessment (EA), is completed and approved by the BEO before the subject activities are implemented.

5.2.7 Compliance with human subject research requirements: The AM, COR shall assure that the IP and sub-awardees, -grantees, and -contractors demonstrate completion of all requirements for ethics review and adequate medical monitoring of human subjects who participate in research trials carried out through this IEE and ensure appropriate records are maintained. All documentation demonstrating completion of required review and approval of human subject trials must be in place prior to initiating any trials and cover the period of performance of the trial as described in the research protocol.

5.3 MITIGATION MEASURES

The mitigation measures presented in this section constitute the minimum required based on available information at the time of this IEE and the environmental analysis in Section 4. These measures shall provide general direction for completing the project/activity Environmental Mitigation and Monitoring Plan (EMMP) and/or the EA and PERSUAP, if required.

PROJECT/ACTIVITY 1: TRUST IN GOVERNMENT INCREASED

TABLE 5A. SUMMARY OF MITIGATION MEASURES FOR PROJECT/ACTIVITY 1

Project/Activity Early Recovery Mitigation Measure(s) Project/Activity 1:1 Pre-liberation community dialogue

No environmental effects anticipated

Sub-activity 1.2 Post liberation dialogue/ neighborhood meetings

No environmental effects anticipated

Sub-activity 1.3 Social reconciliation to promote community cohesion

No environmental effects anticipated

Sub-activity 1.4 Improve access to services through initial investments in public goods (i.e., district administration offices)

Environmental impacts and mitigation requirements of infrastructure and construction activities will depend on the nature and scale of activities. All activities in this category must undergo environmental screening and determination using the ERF (see Annex 2) must be made on the basis of screening.

The ERF should be uploaded into the appropriate sub-folder(s) of this Google Drive folder:https://drive.google.com/drive/folders/1q7HGMzgopJ- MuKxkQEJ4GSPp9R7Qzv-5?usp=sharing.

This will facilitate access by all parties who need these documents, Small scale construction will be defined as:

Total surface area of the disturbed environment is under 10,000 square feet and less than $200,000 total cost. All construction beyond this scale may qualify for Positive Determination.

For Small Scale Construction activities:

• Mitigation measures with no complicating factors, i.e., the site is not within 30 meters of a permanent or seasonal stream or water body, will NOT involve displacement of existing settlement/inhabitants, has an average slope of less than 5 percent and is not heavily forested, in an otherwise undisturbed local ecosystem, or in a protected area. Measures include:

• Construction will be undertaken in a manner generally consistent with the guidance for environmentally sound construction; at minimum,

(1) During construction, prevent sediment-heavy run-off from cleared site or material stockpiles to any surface waters or fields with berms, by covering sand/dirt piles, or by choice of location. (Only applies if construction occurs during rainy season.); (2) Construction must be managed so that no standing water on the site persists more than 4 days; (3) IPs must require their general contractor to certify that it is not extracting fill, sand or gravel from waterways or ecologically sensitive areas, nor is it knowingly purchasing these materials from vendors who do so;

(4) IPs must identify and implement any feasible measures to increase the probability that timber is procured from legal, well-managed sources.

• Worker and Community Safety will be at the forefront of design, planning, and construction activities. Appropriate personal protection equipment (PPE) must be available and utilized for all workers.

Potable water, sanitation facilities, and hand washing facilities must be available at all work sites. A first aid kit must be available during all construction activities with at least one worker on site at any time with the knowledge to use the kit to treat emergency situations. A firm delineation must be in place to keep community members from entering the construction site where they can be exposed to hazards. Fencing must be in place around areas that are hazardous like pits or areas with hazardous materials. Further, workers and community members must be sensitized in HIV/AIDS and STDs transmission.

• Risks Associated with Changing Climate must be accounted for in the design and operation of constructed facilities. All CRM analyses must be approved by the Engineer of Record qualified to incorporate CRM findings into construction designs.

Risks to building design and function will be impacted by increased temperature and increase in extreme weather and climate events. These climate stressors will impact material selection, construction design, and site selection.

• Asbestos: If the presence of Asbestos is suspected in a facility to be renovated, the facility must be tested for asbestos before rehabilitation works begin. Should asbestos be present, then the work must be carried out in conformity with host country requirements, (if any) and in conformity with guidance to be provided by the MEO, in consultation with the REA. All results of the testing for asbestos shall be communicated to the C/AOR. The public, especially children, should be protected from any asbestos-related activities and materials.

• Existing Lead Paint: If the presence of lead paint is suspected in a facility to be renovated, the facility must be tested for lead paint before rehabilitation works begin. Should lead paint be present, then the work must be carried out in conformity with host country requirements, (if any) and in conformity with guidance to be provided by the MEO, in consultation with the REA. All results of the testing for lead paint shall be communicated to the C/AOR. The public, especially children, should be protected from any lead paint-related activities and materials.

• Paint: No lead-based paint shall be used, when lead-free paint is used, it will be stored properly so as to avoid accidental spills or consumption by children;

empty cans will be disposed of in an environmentally safe manner away from areas where contamination of water sources might occur; and the empty cans will be broken or punctured so that they cannot be reused as drinking or food containers.

• Construction Camps for Workers. If a worker camp becomes necessary, it needs to have a management plan in place to reduce the likelihood of negative relations with the host community (such as reducing risks for: security concerns, public health issues, speeding construction vehicles, improper disposal of waste, and illegal hunting or extraction of natural resources). Camps must also have temporary latrines (that will be demolished at the end of construction) and access to potable water and energy for cooking or lighting that does not cause strain on established communal systems.

• Air Quality: Measures must be taken to keep dust (particulate matter) to a minimum during construction on site and in transit to the construction site. The WHO states that there is good evidence short-term exposure to particulate matter with a diameter of less than 10 µm negatively impacts respiratory health.9

• Vegetation Removal / Replanting should be avoided as much as possible for purposes of aesthetics, natural habitats, and erosion control.

Revegetation is required where vegetation was disturbed or destroyed due to construction. Where trees are removed, for every one tree removed, two saplings of a tree species that bears fruit or will become a shade tree must replace the removed tree.

• Site Selection. Selection of sites/learning centers should be closely reviewed by USAID and the IP engineers and planners. As part of the annual work plan approval, USAID and the IP should agree on minimum standards for the sites that will be assessed, approved, and monitored for compliance throughout the implementation period.

• Infrastructure and small-scale construction activities must follow USAID sector guidelines in construction-available at:

https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/seg-construction/pdf

• The COR will ensure the IP develops, obtains approval for, and implements Environmental Mitigation and Monitoring Plans (EMMPs) that are responsive to the stipulated environmental compliance requirements.

• The Mission has a contract with a third-party monitoring and verification company to verify activities.

PROJECT/ACTIVITY 2: INCREASED SOCIAL COHESION WITHIN AND ACROSS COMMUNITIES

TABLE 5B. SUMMARY OF MITIGATION MEASURES FOR PROJECT/ACTIVITY 2

Project/Activity Increasing Connectivity between citizens and local governance

Mitigation Measure(s)

Project/Activity 2: 1 Conduct public awareness and engage the community members in participatory decision making and inclusion.

No environmental effects anticipated

9 WHO Health Effects of Particulate Matter 2013 (http://www.euro.who.int/__data/assets/pdf_file/0006/189051/Health-effects-of-particulate-matter-final-Eng.pdf) https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/seg-construction/pdf https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/seg-construction/pdf https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/seg-construction/pdf

Sub-activity 2.2 Support participatory planning process in targeted communities, including citizen-led implementation of small-scale ‘peace dividend’ activities.

For construction related activities, “small scale” is defined as:

• Total surface area of the disturbed environment is under

10,000 square feet and less than $200,000 total cost.

• The site is not within 30 meters of a permanent or seasonal stream or water body.

• The construction will NOT involve displacement of existing settlement/inhabitants.

• The average slope is less than 5 percent .

• The footprint of the building is located within an area that is heavily forested, in an otherwise undisturbed local ecosystem, or in a protected area.

In addition for small-scale construction:

• All small-scale activities implemented through small grants will be screened using the USAID AFR/ Environmental Review Form…