Attachemnt_J._7_Initial_Environment_Examination_(IEE).pdf

TRACKING ID: #

USAID/SOUTH SUDAN PLATFORM FOR PEACE AND CIVIC SPACE (PPCS) PROJECT IEE

INITIAL ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY DATA

Project/Activity Name: Platform for Peace and Civic Space (PPCS) Project

Amendment (Y/N): N Geographic Location(s) (Country/Region): South Sudan Program Implementation Start/End: 2017- 2023 Solicitation/Contract/Award Number:

Implementing Partner(s): TBD Partners for New Awards.

Multiple: TBD

Tracking ID/link: https://ecd.usaid.gov/document.php?doc_id=50644

Tracking ID/link of Related RCE/IEE (if any):

Tracking ID/link of Other, Related Analyses:

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

USAID/South Sudan

Funding Operating Unit(s):

(e.g., Mission or Bureau or Office)

USAID/South Sudan

Funding Account(s): DA Funding Amount: $357 million Amendment Funding Date: Amendment Funding Amount:

Other Affected Unit(s): N/A Lead BEO Bureau: AFR BEO Prepared by: Angana Roy, Andrea Vargas Guerra, & Josh Habib

(GEMS/Cadmus) Submitted by: Philip Clark Date Prepared: December 2017

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: ☒ Categorical Exclusion ☐ Amendment ☒ Initial Environmental Examination ☐ Deferral

Environmental Determination(s): ☒ Categorical Exclusion ☐ Positive Determination ☒ Negative Determination w/ Conditions

☒ ERR/EMMP ☐ PERSUAP

IEE Expiration Date: Sept. 30, 2023 Additional Analyses/Reporting Required:

Climate Risk Management (CRM), see Sect. 4

Climate Risks Identified (#): Low __X____ Moderate __X____ High ______ Climate Risks Addressed (#): Low ______ Moderate _____ High ______ https://ecd.usaid.gov/document.php?doc_id=50644 https://ecd.usaid.gov/document.php?doc_id=50644

USAID/SOUTH SUDAN PLATFORM FOR PEACE AND CIVIC SPACE (PPCS) PROJECT IEE 2

THRESHOLD DECISION MEMO AND SUMMARY OF FINDINGS

PURPOSE AND SCOPE OF THE INITIAL ENVIRONMENTAL EXAMINATION

The purpose of this Initial Environmental Examination (IEE), in accordance with Title 22, Code of Federal Regulations, Part 216 (22CFR216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the activities planned in the USAID/South Sudan Platform for Peace and Civic Space (PPCS) Project under Transition Objective 2 (TO2). This IEE also provides recommended determinations and, as appropriate, conditions, for these PPCS activities. Upon approval, these determinations become affirmed, per 22CFR216, and specified conditions become mandatory obligations of implementation. This IEE also provides an initial screening of the results of the project-level Climate Risk Management process, in accordance with USAID policy (specifically, ADS 201mal).

This IEE is a critical element of the USAID mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation. Potential environmental impacts should be addressed through formal environmental mitigation and monitoring plans (EMMPs).

PROJECT/ACTIVITY SUMMARY

The Platform for Peace and Civic Space (PPCS) Project aims to promote stability, local solutions, and citizen participation to mitigate conflict, advance reconciliation efforts, increase access to and strengthen independent media. PPCS will be the primary tool for USAID/South Sudan to provide flexible, strategic responses to peace and civil-society strengthening opportunities in South Sudan and between Sudan and South Sudan. PPCS will support cooperation at the local, regional, national and international levels, between key actors and initiatives. PPCS will adapt to the fluid South Sudan and regional political environment and contribute to the achievement of U.S. Government humanitarian and diplomatic objectives.

ENVIRONMENTAL DETERMINATIONS

The following table summarizes the recommended determinations based on the environmental analysis conducted for PPCS activities. Upon approval of this document, the determinations become affirmed, per Agency regulations (22CFR216).

TABLE 1: ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion Negative Determination

Positive Determination Deferral

Activity 1: Small-scale Infrastructure Projects

X (w/ conditions)

Activity 2: Media, Outreach and Communications X Activity 3: Community Engagement and Economic Development X Activity 4: Awareness and Education Campaigns X Activity 5: Sociocultural Peacekeeping Interventions X

USAID/SOUTH SUDAN PLATFORM FOR PEACE AND CIVIC SPACE (PPCS) PROJECT IEE 3

CLIMATE RISK MANAGEMENT

A moderate risk has been established for construction and building use and WASH activities due to increased temperatures and extreme weather events (e.g., drought, flooding). An initial CRM screening, as required by ADS 201, has been completed for construction and WASH activities and has been included in this IEE in section 4.2.

BEO SPECIFIED CONDITIONS OF APPROVAL

1. Mission Activity Manager Role. Should the activity, as observed by the Mission Activity Manager or the Contract Officer’s Representative (COR) (or their designee), identify potential adverse impacts not previously identified, the Activity Manager will notify the MEO and COR will cease operations until the appropriate environmental analysis can be completed.

2. Environmental Mitigation and Monitoring Plans (EMMPs)/Environmental and Social Management Plans (ESMPs). All construction activities under this project, except for studies and planning, must be assessed for environmental impacts.1 Construction activities deemed to generate moderate risks will require preparation of site-specific management plans for potential environment and social impacts. These plans should provide sufficient information for meaningful monitoring of efforts to reduce foreseen environmental impacts including: 1) descriptions of moderate- and high-risk activities, 2) a description of environmental characteristics of the site(s) of the proposed, 3) an account of all regulatory licenses and approvals required for the activity to ensure the activity will be in line with sound environmental management practices, 4) an evaluation of activities and issues with respect to potential negative environmental impacts, and (5) an environmental-mitigation action that specifies mitigation measures, monitoring, responsible parties and other information, such as site maps, plans and site drawings. The implementing entity will submit the draft EMMP/ESMP to the COR, MEO and REA for review and concurrence. The AFR EMMP Factsheet provides guidance and sample EMMP formats:

http://www.usaidgems.org/mitMonRep.htm.

3. Climate Risk Management (CRM). Activities not already determined to be low risk must undergo climate-risk assessment. An initial CRM screening, as required by ADS 201, has been completed for construction and has been included in this IEE in section 4.2. This is an initial CRM assessment. The responsibility for assessing and addressing climate risk lies with the engineer-of-record. Thus, CRM will be a component of the engineering design and the results will have to be included in the EMMP/ESMP.

4. Compliance Documentation and Reporting. The implementing entity or contractor or firm will be responsible for submitting to the COR and MEO an Environmental Management and Mitigation Report (EMMR) documentation of compliance with conditions of the IEE mitigation measures described in EMMP. The EMMR will be submitted periodically, preferably before construction, during construction and before operation. The EMMR must contain sufficient evidence demonstrating compliance of both IEE and

EMMP.

5. Water Supply and Sanitation: Good-practice design standards will be specified in the EMMP/ESMP and must include siting of new wells far from groundwater-contamination sources (e.g., latrines, cesspits, dumps), exclusion of livestock from water points, prevention of standing water at water supplies, provision

1 It is important to note that assessment of environmental impacts for construction activities implemented by Public International Organizations (PIOs) will be consistent with ADS 308.3.11(c), which provides that “[a]ny environmental conditions proposed to ensure adequate environmental review of the activity proposed should have due regard to both the independence and sovereignty of the PIO and the purpose and intent of the environmental impact assessment requirements of USAID.”

http://www.usaidgems.org/mitMonRep.htm

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of latrines with handwashing stations, especially at sites where people are expected to spend significant portions of their time. These steps must be consistent with the USAID Sector Environmental Guidelines:

Water Supply & Sanitation:

http://www.usaidgems.org/Documents/SectorGuidelines/Wat%20San%20Guideline%20Final_w_GCC_Ad dition__May11.pdf.

A Water Quality Assurance Plan (WQAP) must be a part of the EMMP and approved by the Mission Environment Officer (MEO). The WQAP is intended to ensure all new and rehabilitated USAID-funded water supplies provide safe drinking water, defined as meeting local and WHO water-quality standards.

Critical parameters to be tested include arsenic, fecal coliform, fluoride, nitrate, electrical conductivity, total dissolved solids, ph and turbidity. These parameters will be analyzed during commissioning and at least twice within the first year of commissioning. The WQAP template can be found here:

http://www.usaidgems.org/wqap.htm.

6. Construction Risk Screening must be done for each activity and address conformance with, or variation from, each of the principal elements within USAID’s preferred approach to construction (Construction Risk Mandatory Reference https://www.usaid.gov/sites/default/files/documents/1865/201maw.pdf). The screening should be organized to describe actions taken or planned to mitigate construction risk at different stages of activity implementation: Planning, Engineering Design, Construction Procurement, and Implementation.

7. Protection and Sustainable Use of Natural Resources. Extraction and harvesting of sand for construction works must be done only in approved waterways. Mitigation measures against adverse environmental impacts from sand extraction must be developed. Timber should be sourced from licensed vendors, and USAID funds will not be used to procure timber from unsustainable sources.

8. Environmental Monitoring Responsibilities. As required by ADS 204.3.4, the implementing entity or

Contractor will “actively monitor ongoing construction activities for compliance with approved IEE recommendations, conditions, and mitigation measures.” If new or unforeseen environmental consequences arise during implementation the COR will suspend the activity and initiate an appropriate further review in accordance with 22 CFR 216. USAID monitoring shall include regular site visits, at times with the MEO accompanying the COR or designate in the field, and the regular review of reported environmental monitoring indicators from the IP or Contractor (often synchronized with the reporting of performance indicators). Specifically, the implementing entity or Contractor shall engage the services of full time Environmental Compliance Officer responsible for monitoring and ensuring compliance of all activities construction works with the IEE and EMMP/ESMP.

IMPLEMENTATION

In accordance with 22CFR216 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.

http://www.usaidgems.org/Documents/SectorGuidelines/Wat%20San%20Guideline%20Final_w_GCC_Addition__May11.pdf http://www.usaidgems.org/Documents/SectorGuidelines/Wat%20San%20Guideline%20Final_w_GCC_Addition__May11.pdf http://www.usaidgems.org/wqap.htm

USAID/SOUTH SUDAN PLATFORM FOR PEACE AND CIVIC SPACE (PPCS) PROJECT IEE 6

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE AND SCOPE OF IEE

The purpose of this Initial Environmental Examination (IEE), in accordance with Title 22, Code of Federal Regulations, Part 216 (22CFR216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the activities planned in USAID/South Sudan Platform for Peace and Civic Space (PPCS) Project. This IEE also provides recommend determinations and, as appropriate, conditions, for these PPCS activities. Upon approval, these determinations become affirmed, per 22CFR216, and specified conditions become mandatory obligations of implementation. This IEE also provides an initial screening of the results of the project-level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

This IEE is a critical element of the USAID mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation. Potential environmental impacts should be addressed through formal environmental mitigation and monitoring plans (EMMPs).

1.2 PROJECT OVERVIEW

The Platform for Peace and Civic Space (PPCS) Project aims to promote stability, local solutions, and citizen participation to mitigate conflict, advance reconciliation efforts, increase access to independent media, and empower civil society, e.g., current TO2 programs Viable Support to Transition and Stability (VISTAS), Abeyi Rehabilitation Initiative (ARI IV), Reconciliation for Peace in South Sudan (RfP), Promoting Resilience through Ongoing Participatory Engagement and Learning (PROPEL), Strengthening Free and Independent Media in South Sudan (I-STREAM), and Systems to Uphold the Credibility and Constitutionality of Elections in South Sudan (SUCCESS).

PPCS will be the primary tool for USAID/South Sudan to provide flexible, strategic responses to peace and civil-society strengthening opportunities in South Sudan and between Sudan and South Sudan. PPCS plans to support cooperation at the local, regional, national and international levels, between key actors and initiatives. PPCS will need to adapt to the fluid South Sudan and regional political environment and contribute to the achievement of U.S. Government humanitarian and diplomatic objectives.

Under the TO2 Objective: Enable peace and reconciliation processes, PPCS supports conflict mitigation and social cohesion, while providing for assistance to the implementation of critical aspects of the August 2015 peace agreement. PPCS supports the integration of governance, conflict mitigation, and community-based trauma awareness, justice and reconciliation.

Assuming the continued volatility of the South Sudan operating context and the likelihood of PPCS program implementation in a politically sensitive context, the program will be built upon three strategic pillars: flexibility, control and integration. The USAID Mission in Juba requires a mechanism simultaneously to maintain situational and contextual awareness and to align with competing priorities for South Sudan and the region.

Drawing on best practice and lessons learned from similar programs in South Sudan, Abyei, and elsewhere, the Mission will play a critical role in making the PPCS a strategic and targeted tool. Mission PPCS management will be “hands on,” applying knowledge and expertise of the implementer and USAID staff and of technical experts who will oversee performance management.

USAID/SOUTH SUDAN PLATFORM FOR PEACE AND CIVIC SPACE (PPCS) PROJECT IEE 7

While the prospects for national-level accord have dimmed since the violence of July 2016, the international community continues to obtain favorable results when engaging at the sub-national level.

Meaningful national change will also require generational transition and the development of an inclusive and open national political environment. In the meantime, given the failure of neighboring states and international stakeholders to pressure bad actors in South Sudan, concerned international donors should invest in the future generation through support to civil society and credible public-sector actors demonstrating a desire to assist their constituents. This support should include investment in civil-society and non-governmental institutions that promote a social and political climate -- especially in local areas --in which these actors can thrive and act on the needs of society, rather than for personal or sectarian advancement. Targeted integrated assistance to these identified good performers and organizations cannot only improve the lives of many South Sudanese living in these islands of relative stability, but, also, through promotion of information-sharing and consensus building, identify promising “next generation” leaders and local groups and highlight successful experiences and practices.

1.3 PROJECT DESCRIPTION

Table 2 provides of the list of the illustrative activities covered by USAID/South Sudan PPCS Project.

Section 3 of this IEE provides a fuller description of the portfolio of activities in PPCS.

TABLE 2: ILLUSTRATIVE ACTIVITIES UNDER PPCS

Support to local peace-minded actors (e.g., traditional authorities, women’s groups, civil-society organizations, interest groups, conscientious local authorities) via small-scale rehabilitation of premises and facilities from which to operate and provision of basic equipment and materials (e.g., desks, cabinets, stationery, computer equipment and generators) Commerce-based activity that provides small-scale infrastructure (e.g., cattle pens, simple river dock structures) that encourages two or more groups in conflict to cooperate Quick employment through rehabilitation of community centers, clinics, etc.

WASH-linked activities such as drilling of boreholes and installation of latrines that can reduce conflict Technical assistance and support to launch and manage peace and coexistence mechanisms and support political processes by engaging communities, local administrations and civil society Skills training, employment and entrepreneurial opportunities for targeted communities Support for community-based efforts that mitigate conflict through efforts to increase communities’ awareness of the collective benefits of environmental and wildlife protection Cultural and sporting events that peacefully bring together South Sudanese of diverse backgrounds Dissemination of peace messaging Peace-directed activities that bring together large numbers of youth and/or women Organization of civic-engagement fora and civic-awareness campaigns on issues such as reform, good governance, reconciliation, and accountability Civilian monitoring initiatives on peace agreement(s) and peace processes Development of innovative systems to safely document and collect in a standardized, high-quality fashion information on human rights and other abuses Sponsorship of human-rights defenders and transitional justice actors’ participation in regional and international human rights meetings Training of individuals who will then directed to engage with communities and groups on trauma awareness Production and dissemination of materials promoting trauma awareness Dissemination of information on peace processes Promotion and encouragement of civil debate and organization of activities to counter hate speech Eye Radio-Broadcasts news and entertainment 24 hours daily from Juba and through nationwide repeater network Support of community radio stations- Singaita FM in Kapoeta (Eastern Equatoria), Mayardit FM in Turalei (Warrap), Akol Yam FM in Aweil (Northern Bahr el Ghazal), Mingkaman FM in Mingkaman (Lakes), Nile FM in Malakal (Upper Nile), Kondial FM in Bentiu (Unity) and Abyei Today (through broadcasting on Mayardit FM & Akol Yam FM).

USAID/SOUTH SUDAN PLATFORM FOR PEACE AND CIVIC SPACE (PPCS) PROJECT IEE 8

Humanitarian Information Service -- Providing critical information to displaced populations not reached by conventional media, including humanitarian services news in Juba, Bentiu, and Malakal, e.g., PPCS Media Activity.__________________________________________________________________________ Upgrading water yards, i.e., water sources, typically for livestock, Grants to local partners -- The small-grants program is designed to include partners with a range of a different backgrounds and varying capacities – from established media houses to youth tech start-ups.

Rehabilitating schools, health facilities, traditional courts and other small-scale infrastructure in support of conflict-mitigation objective.Upgrading water yards, increasing availability and access to water along cattle-migration routes.

Providing vocation and informal-livelihoods, business skills, English literacy, peacebuilding and conflict-mitigation training and dialogues.

2.0 BASELINE ENVIRONMENTAL INFORMATION

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL)

2.1.1 LOCATIONS AFFECTED

The project will take place in various regions across the nation.

Development programs will coordinate closely with related USG humanitarian efforts in a layered, sequenced and integrated manner. Programming will focus on conflict-affected areas with high concentrations of internally displaced persons (IDPs) and returnees. Ongoing conflict analysis will inform choices for targeting programming.

With this geographic concentration, the Framework anticipates opportunities for collaborative work across all sectors (health, education, democracy and governance, economic growth, conflict mitigation and humanitarian assistance).

Any peace building work in South Sudan must consider the disputed region of Abyei. An oil-rich region of Sudan, Abyei has been a key location of conflict since the beginning of the civil wars. It has served historically as the bridge between the North and South of Sudan. An entire chapter of the Comprehensive Peace Agreement, signed in 2005, that was meant to end the Second Sudanese Civil War, is dedicated to the Abyei Conflict. The CPA determined that during the interim period, before the South Sudan independence referendum, the Abeyi Administrative Area, as it would now be called, would have a unique administrative status. Residents would be simultaneous citizens of both Western Kordofan (now a state of Sudan) and Bahr el Ghazal (now a state of South Sudan). Oil revenues would be divided among the National Government, the Government of Southern Sudan, both state regions, and locally between the two tribes in the region. After the referendum in South Sudan, Abeyi was to have a referendum of its own

SEQ Figure \* ARABIC

USAID/SOUTH SUDAN PLATFORM FOR PEACE AND CIVIC SPACE (PPCS) PROJECT IEE 9

to determine whether it would maintain its special administrative status in the north or become a part of Bahr el Ghazal.2 This official referendum has yet to take place, due to a variety of disagreements, including questions of voter eligibility. The region remains in dispute, with many humanitarian actors present in hope of maintaining calm in the conflict-prone region. USAID is currently there, implementing the Abeyi Rehabilitation Initiative.3

2.1.2 SOCIAL CONTEXT

South Sudan is struggling with the legacy of protracted civil war that has torn the fabric of society and created one of the world’s worst humanitarian crises. One third of the population is displaced, half is food insecure, and the economy has collapsed. Gender-based violence is widespread. On the national scale, a little under half of the population in South Sudan is living on less than $1.90 (in 2011 $PPP) per day and

50.6 percent of the population is living under the national poverty line.4 The country is facing an extreme humanitarian crisis that has displaced 1.9 million persons and has left 6 million in need of food assistance.5 These statistics are staggering, considering the population of South Sudan is 12.3 million.6

Various humanitarian organizations, including USAID/OFDA and USAID Office of Food for Peace (USAID/FFP) partners, are responding to food insecurity, malnutrition, health and protection needs across South Sudan, including continued support to areas affected by both conflict and recent flooding in the Jonglei State.7 Insecurity, landmines, and limited transportation and communication infrastructure are the main barriers to humanitarian activities across the country. These barriers severely limit the delivery and effectiveness of assistance aid to those who are in need.

2.1.3 CLIMATE CONTEXT

According to the National Adaptation Programmes of ACTION (NAPA) to Climate Change, a variety of factors contribute to the current vulnerability to climate variability in South Sudan. Traditional subsistence agriculture is the dominant livelihood of 78 percent of South Sudanese households. These individuals rely heavily on crop farming and animal husbandry, which typically depend upon traditional farming methods, leaving this population highly vulnerable to climate variability. Both droughts and flooding can cause crop and livestock loss.8 In addition to affecting individual South Sudanese, climate change also threatens the economy of the country more broadly. Agricultural investments made in hope of growing the sector could be lost. These climate changes also could damage the forestry sector of the economy, upon which many South Sudanese rely upon9.

Since independence, demand has increased for natural resources, particularly charcoal and fuelwood, dramatically accelerating deforestation. Deforestation can increase the climate vulnerability of rural populations, as local ecosystems can no longer act as buffers to mitigate the effects of erratic rainfall, floods, and droughts. Soil erosion has also caused the reduction of water supply for both drinking and irrigation, as well as affecting soil quality, and therefore agricultural productivity.10

2 https://peaceaccords.nd.edu/sites/default/files/accords/SudanCPA.pdf 3 https://www.iom.int/news/usaid-extends-abyei-rehabilitation-initiative 4 UNDP data 5 South Sudan Fact Sheet 6 UNDP data 7 South Sudan Fact Sheet 8 Republic of South Sudan. 2016. National Adaptation Programmes of Action (NAPA) NAPA. Available online at:

https://postconflict.unep.ch/publications/South%20Sudan/SouthSudan_NAPA_Nov2016.pdf 9 USAID. 2013. Climate Vulnerability Profile. Available at:

https://www.climatelinks.org/sites/default/files/asset/document/south_sudan_climate_vulnerability_profile_jan2013.pdf 10 Republic of South Sudan. 2016. National Adaptation Programmes of Action (NAPA) NAPA. Available online at:

https://postconflict.unep.ch/publications/South%20Sudan/SouthSudan_NAPA_Nov2016.pdf https://peaceaccords.nd.edu/sites/default/files/accords/SudanCPA.pdf

USAID/SOUTH SUDAN PLATFORM FOR PEACE AND CIVIC SPACE (PPCS) PROJECT IEE 10

Climate projections for South Sudan predict increasing average temperatures, increasingly unpredictable seasonal rains and greater intensity of rainfall events, as well as an increased incidence of drought.11 IDPs and vulnerable groups, including women and children, as well as the communities housing IDPs, may be threatened by climate change. Loss of agricultural productivity and livestock, diminished availability and quality of water, and capacity of sanitation systems are all potential risks.12

Disasters and extreme weather events put women and children at risk while fetching water, travelling to school, and collecting firewood. Women and the poor are more likely than others to live high-risk lives or have high-risk livelihoods, as they are compelled to find needed resources in flood- and drought-prone areas. High water levels can make water-fetching dangerous, and these groups might be exposed to water contaminated with sewage during floods. Droughts can lead to increased forest and brush fires, further threatening firewood gatherers, primarily women. Household conflicts might also increase due to climate-related stress over household incomes. For example, conflict over pastoral lands may translate to violence at home.

Greenhouse Gas (GHG) emissions are generally low in South Sudan, but the emissions generally come from land-use change, such as burning/deforestation for agriculture, and electricity production. Some 90 percent of the population relies on wood fuel and charcoal, which also contributes to GHG and removes carbon from sequestration in forests.13

2.1.4 ENVIRONMENTAL CONTEXT

South Sudan covers about 640,000 square kilometers. It includes stretches of tropical and equatorial forests, wetlands (including the Sudd swamps), savannah and mountains. Vegetation in the South is characterized by Sudanian woodlands, with lowland forest patches along the border with the Democratic Republic of the Congo and the Imatong Mountains. Extensive swamps and floodplains lie along the White Nile. The most important mountain forests in the Sudan are in the Imatong Mountains in the extreme south, including Didinga and Dongotono Mountains. South Sudan is entirely within the Nile River basin and shares borders with The Central African Republic, The Democratic Republic of the Congo, Ethiopia, Kenya and Uganda.

Most of South Sudan has a semi-humid climate, with annual rainfall ranging from 200 mm in the Southeast (Eastern Equatoria) to 1200-2200mm in the forest zone in Western Equatoria and the Equatorian highlands. In the Northern states, rainfall varies between 700-1300 mm. The rainy season lasts from April to December and causes seasonal flooding. Temperatures in South Sudan are typically above 25°C and can rise above 35°C, particularly during the dry season, which lasts from January to April. The hot, dry conditions trigger seasonal human and livestock migration to more permanent water sources (the toic), which serve as dry-season grazing pasture, and for some ethnic groups, such as the Dinka, they also serve as fishing grounds.14

11 USAID. 2016. Climate Risk Profile. Available at:

https://www.climatelinks.org/sites/default/files/asset/document/2016%20CRM%20Fact%20Sheet%20-%20South%20Sudan_0.pdf 12 USAID. 2013. Climate Vulnerability Profile. Available at:

https://www.climatelinks.org/sites/default/files/asset/document/south_sudan_climate_vulnerability_profile_jan2013.pdf 13 USAID. 2016. Greenhouse Gas Emissions in South Sudan. Available at:

https://www.climatelinks.org/sites/default/files/asset/document/2017_USAID_GHG%20Emissions%20Factsheet_South%20Sudan.pdf 14 Brown, Agricultural Productivity and Marketing Assessment Report, May 2009.

Catterson et al, Sudan Environmental Threats and Opportunities Assessment, USAID, 2003.

Catterson et al, Programmatic Environmental Assessment of Road Rehabilitation Activities in Southern Sudan, first draft, 2006.

Menczer Karen et al, Southern Sudan Environmental Threats and Opportunities Assessment: Biodiversity and Tropical Forest Assessment, USAID, 2007.

Walsh, USAID Initial Environmental Examination for Sudan SOs 9, 10, and 11, 2006.

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South Sudan suffers from inadequate potable water, declining wildlife populations because of warfare and excessive hunting, soil erosion, desertification, and periodic droughts and floods. Pollution is also an issue, due to oil and charcoal production and deforestation. At the intersection of climate change and environmental degradation, deforestation has had major negatives impacts on water, soil and biodiversity.

Deforestation is driven by the collection of fuelwood, charcoal production, brick making and collection of construction materials. South Sudan also has potential economic and social well-being opportunities, including low population density in relation to a significant wealth of basic primary resources, such as abundant water, good soils, relatively high rainfall, and potentially good forest cover if deforestation is halted.15

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS (E.G. WHO), ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS

2.2.1 SOUTH SUDAN ADMINISTRATION, LAWS, AND POLICIES-ENVIRONMENT

South Sudan has five administrative levels: national, state, county, payam and boma. Ministries are established at both national and state levels. Below these levels, the administrations have departments or units for the various sectors. The Ministry of Environment and Forestry is responsible for the development and implementation of environmental policy and legislation.

The Ministry of Environment and Forestry responsibilities include: developing and implementing policies on environmental protection and conservation, establishing government environmental policy and monitoring its effectiveness and impact, creating programs in collaboration with other Ministries for the control of environmental degradation and control of desertification, developing Environmental Impact Assessment standard methodologies and procedures for government development policies and private sector investment, advising and supporting state and local governments in their responsibilities for environment and building their capacity to assume all functions vested by the Constitution and government policy. Environmental policy has not yet been shaped at the state and local levels. Only a few states have environmental directorates attached to one of their Ministries.

The South Sudan National Environmental Policy 2015-2020 establishes partnerships and coordination for the monitoring and evaluation of environmental strategies and programming among partners. All environmental international, regional, and domestic laws will also be overseen through the policy. The South Sudan National Environmental Authority, articulated arrangements for the integration and mainstreaming of the environmental policy in line ministries and lower level governments. The National Environmental Authority uses Environmental Liaison Units and State and Local Environmental Committees for implementation of five-year Environmental Action Plan, which addresses: (1) implementation of environmental analysis and environmental audits and monitoring; and (2) land use and planning and the protection of wetlands, lakes, rivers, hilly and mountainous areas, biodiversity, forests, rangelands, national heritage and the ozone layer.

The South Sudan National Environmental Policy and Environmental Bill form a basis for sustainable environmental management but the challenge will be making it work. The goal is to undertake policy and action in energy generation and use, land-use change, and transport. Current signs of environmental mismanagement and their consequences, such as riverbank erosion, invasive species, pesticide mismanagement, water and soil pollution, streams, rivers and canals sedimentation, deforestation and conflicts among resource users, call for implementation of policies addressing these issues.16 The South Sudan Framework and Environmental Bill include addressing the drivers of environmental degradation

15 http://www.ss.undp.org/content/dam/southsudan/library/Reports/southsudanotherdocuments/EIRO%20Report-fr-website.pdf

16 http://www.ss.undp.org/content/dam/southsudan/library/Reports/southsudanotherdocuments/EIRO%20Report-fr-website.pdf http://www.ss.undp.org/content/dam/southsudan/library/Reports/southsudanotherdocuments/EIRO%20Report-fr-website.pdf http://www.ss.undp.org/content/dam/southsudan/library/Reports/southsudanotherdocuments/EIRO%20Report-fr-website.pdf

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and mitigation of climate change while also considering economic development. Adaptation of vulnerable communities will include capacity building for participation in community organizations by a diverse set of stakeholders in climate change planning as well as increasing investments in early warning systems and disaster response. The INDC also notes that an objective for infrastructure resilience to climate change is ensuring land use and building codes reflect expected impacts of climate change and are resilient.

2.2.2 SOUTH SUDAN ADMINISTRATION, LAWS, AND POLICIES-LAND GOVERNANCE

Land governance is intrinsically related to the conflict affecting South Sudan. Land disputes have surged recently as demand for land has increased. An effective approach to land issues could break the cycle of conflict and facilitate post-conflict economic recovery. The South Sudanese government has been trying to address these land issues since the signing of the Comprehensive Peace Agreement (CPA) in 2005.

This agreement enacted various new laws and created new institutions. As a new country, South Sudan faces the challenge of having to build new institutions upon the old. The development of the Land Act of 2009, which reinforces government recognition of customary land tenure and puts a ceiling on land allocations, and the new National Land Policy of 2013, are steps forward, but the lack of human and financial resources inhibits the effectiveness of these policies and institutions.

The four main post-conflict issues that South Sudan must face regarding land issues are: 1) spill-over tensions related to land and natural resources that contributed to the conflict in the first place, 2) unmet demand for land by returning refugees and Internally Displaced Persons (IDPs), 3) the dismantling of statutory and traditional institutions of land governance, and 4) proliferation of arms that increase tensions over land, water and other resources.

Another land-governance issue is that less than 10 percent of rural communal land is documented. The rest is informally administered by traditional institutions, that, as mentioned above, are changing due to the conflict. This legal uncertainty leaves large amounts of communal land vulnerable to unlawful expropriation. Urban land also faces these legal uncertainties, as demand for land outpaces the current registration processes. The law affords women equal rights to own land, but acknowledges that, in practice, these rights will not be respected in many parts of South Sudan. The Land policy states women’s land rights are conditional, depending on marital or childbearing status.17

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISKS

This section describes the portfolio of activities in South Sudan and analyzes the potential for adverse environmental, social, and climate impacts. The program activities/interventions are organized into the following Intervention Categories for the purposes of this evaluation:

1.) Small-scale infrastructure projects, 2.) Media, outreach, and communications, 3.) Community engagement and economic development, 4.) Awareness and education campaigns, 5.) Sociocultural peacekeeping interventions.

The subsections below detail the activities under each category and discuss the conditions under 3.1 and the categorical exemptions for the activities contained under 3.2–3.5. The negative determinations with conditions under 3.1 are related to small-scale infrastructure projects. While activities identified under 22 CFR 216.2(c)(3)(d) are generally recognized as having significant impact on the environment, small-scale

17 “Land Governance in South Sudan: Policies for Peace and Development,” May 2014, Report No. 86958-SS, The World Bank.

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rehabilitation and sanitation projects are not expected to have the same level of impact. Small-scale infrastructure projects to improve living conditions, agricultural activity, and bolster employment are unlikely to have an adverse impact on the surrounding environment, provided the conditions detailed in section 3.1 are met. The effects of small projects can be mitigated through best practices for construction and sanitation. Responsible environmental management plans will focus on minimizing runoff from construction sites and creating safe working and operating conditions around water sources. The conditions for undertaking small-scale infrastructure projects in South Sudan without adverse environmental impacts will need to be addressed at the planning stage of these projects.

3.1 SMALL-SCALE INFRASTRUCTURE PROJECTS

A. Rehabilitating schools, health facilities, traditional courts and other small-scale infrastructure in support of conflict mitigation objectives.

B. Support to local peace-minded actors, e.g., traditional authorities, women’s groups, civil-society organizations, interest groups, conscientious local authorities, via small-scale rehabilitation of premises and facilities from which to operate and provision of basic equipment and materials, e.g., desks, cabinets, stationery, computer equipment and generators.

C. Upgrading water yards, increasing availability and access to water along cattle-migration routes.

D. Rehabilitation of small-scale infrastructure (e.g., cattle pens, simple river dock structures, market stalls) supporting commerce-based activities and encouraging groups in conflict to cooperate.

E. WASH-linked activities, such as drilling of boreholes and installation of hand pumps, construction of latrines, etc.

The small-scale infrastructure projects in the South Sudan portfolio are intended to improve education and civic engagement, sanitation, and economic opportunity. Although small-scale infrastructure projects can benefit communities, they also can cause unintended harm if projects are not planned, executed, or managed properly. Small infrastructure projects can cause environmental disturbances and can result in waste-management issues, including runoff from construction sites. In addition, sanitation projects can result in contamination if not properly planned and managed.

The conditions for managing the environmental risks require following sound building practices and appropriate sanitation protocols, in accordance with the guidelines developed by USAID and other allied organizations. Rehabilitation projects are important for education and community engagement, and the potential adverse impacts can be mitigated using construction best practices and proper environmental management. USAID or affiliate organizations may be needed to support local community efforts to construct and manage projects in an environmentally safe manner.

Rehabilitation of schools, health facilities, traditional courts, and other infrastructure in support of conflict mitigation may require transportation and installation of construction materials and site-specific waste management plans. Sites near water or residences might have different considerations from those in dry or remote areas. Construction sites should minimize runoff and other common construction-related environmental effects. While new construction projects can affect local ecosystems, rehabilitation projects might have less effect on the environment if they do not require land use beyond the footprint of the existing structure. Generators can require additional energy expenditure but environmental harm from installing electrical equipment or infrastructure needed for generators can be mitigated by use of high-efficiency technology or solar energy.

Water-access projects along cattle routes and commerce-based activities can improve economic opportunities for local communities, and certain projects, such as cattle pens and simple river dock

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structures, can encourage groups in conflict to cooperate. Runoff or contamination from improperly installed and managed infrastructure projects near water sources can harm water quality. A single water source can serve multiple communities, and water-quality issues can have wide-ranging effects on human health, cattle and livestock, agriculture, and wildlife. A poorly designed or poorly managed project can have a large, damaging impact on the surrounding communities. As such, it is important that even small-scale infrastructure projects follow construction best practices and proper environmental management techniques. Communities might need technical assistance from USAID or affiliate organizations to construct and manage projects in an environmentally safe manner.

WASH-related activities are critically important for both development and as useful tools in peace-keeping. Sanitation and clean water are universal human rights, and equitable access to sanitary infrastructure and drinking water can have a role in reducing conflict18. In addition, WASH activities should be considered essential government services, a broad category USAID has identified as part of the operational framework for stabilizing South Sudan. The infrastructure needed in some areas of South Sudan might have an environmental impact, but the best practices advocated by USAID and other development agencies are designed to mitigate potentially negative effects of latrines and other necessary sanitation infrastructure. WASH practices outlined by UNICEF standards, for example, are targeted towards developing countries, such as South Sudan. When properly installed, latrines and other sanitation infrastructure can improve certain environmental indicators, particularly environmental health indicators.

Sanitation systems also reduce the risk of water or food contamination and create safer, healthier environments.

3.2 MEDIA, OUTREACH, AND COMMUNICATIONS

A. National radio stations that broadcast news and entertainment nationwide, such as Eye Radio.

B. Community radio stations-- such as Singaita FM in Kapoeta (Eastern Equatoria), Mayardit FM in

Turalei (Warrap), Akol Yam FM in Aweil (Northern Bahr el Ghazal), Mingkaman FM in Mingkaman (Lakes), Nile FM in Malakal (Upper Nile), Kondial FM in Bentiu (Unity) and Abyei Today (through broadcasting on Mayardit FM & Akol Yam FM).

C. Humanitarian Information Service -- Providing critical information to displaced populations not reached by conventional media, including humanitarian services news in Juba, Bentiu, and Malaka.

D. Grants to local partners -- The small-grants program is designed to include partners with a range of a different backgrounds and varying capacities – from established media houses to youth tech start-ups.

E. Radio, film and televised segments.

F. Dissemination of information on peace processes.

G. Complementary physical and other investment alongside other media/information activities.

Media, outreach, and general communication activities are not expected to have adverse environmental impacts. The focus of these activities is on reaching community members and vulnerable populations alike and promoting critical information, such as details about humanitarian services and peace processes.

Effective media channels and communication with the public are important components to development and peace-keeping efforts. Displaced populations and other hard-to-reach populations in particular can learn about access essential services through radio or other media channels. Support for vulnerable populations is a key step in rebuilding communities post-conflict. The development and dissemination of content via radio shows or other media are not associated with any environmental disturbances. As such, 18 https://www.odi.org/sites/odi.org.uk/files/odi-assets/publications-opinion-files/8123.pdf https://www.odi.org/sites/odi.org.uk/files/odi-assets/publications-opinion-files/8123.pdf

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media channels and communication efforts that make use of existing infrastructure are not expected to adversely affect the environment.

The media, outreach, and communications activities outlined for South Sudan focus on document and information transfers and institutional grants. These activities are categorically excluded per 22 CFR 216.2(c)(2)(v) and 22 CFR 216.2(c)(2)(vii).

3.3 COMMUNITY ENGAGEMENT AND ECONOMIC DEVELOPMENT

A. Technical assistance to civil-society organizations, networks, and coalitions.

B. Providing vocational and informal-livelihoods, business skills, English literacy, peacebuilding and conflict-mitigation training and dialogues.

C. Providing technical assistance and support to launch and manage peace and coexistence mechanisms and support political processes by engaging communities, local administrations and civil society.

D. Providing skills training, employment and entrepreneurial opportunities for targeted communities.

E. Quick employment through rehabilitation of community centers, clinics, etc.

F. Engaging women as equal partners in the political and economic process.

These activities are not expected to have any impact on the environment. Community engagement and economic development in South Sudan will focus on training and technical assistance to facilitate conflict-resolution. Community engagement in South Sudan is part of the peace process19. Engaged citizens can participate in local government, which in turn can provide essential services back to the citizens. Strong and cooperative local governments can serve as a foundation for a stable nation while inclusive and sustained civic engagement can help reduce conflict. Parallel efforts by the UNDP have also focused on the role of women in creating local governments and in promoting and sustaining peace.

Providing women equal access to education and political processes is a key indicator of development and is considered vital to the peace process.20 In additional to technical assistance, training and support for these activities is likely to include meetings, education, and information transfers.

Similarly, economic development can provide opportunities for cooperation among conflict groups and is considered a key step to reducing poverty and improving the quality of life in developing countries21.

Nearly half the South Sudan population lives at or below the poverty line22. Skills-based training paired with community-rehabilitation projects can quickly improve the economic opportunities within a community. Targeted outreach to women can decrease the gender gap in South Sudan. Current programs might not be tailored to help female heads of households, for example. 23 None of the activities outlined under this category is expected to have an adverse environmental impact.