ASHA FY 2019-2023 Global IEE.pdf

USAID ASHA FY 2019-2023 GLOBAL IEE 1

INITIAL ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY DATA

Project/Activity Name: FY19-23 Global Initial Environmental Examination (IEE) for Commodity Procurement, Capital Improvements, and Activities involving Pesticides

Amendment (Y/N): N Geographic Location(s) (Country/Region): Worldwide Implementation Start/End: 2019-2023 Solicitation/Contract/Award Number: Various Implementing Partner(s): Various Tracking ID/link: https://ecd.usaid.gov/document.php?doc_id=51140 Tracking ID/link of Related RCE/IEE (if any): FY15-19 ASHA P-IEE:

https://ecd.usaid.gov/repository/pdf/39411.pdf Tracking ID/link of Other, Related Analyses: N/A

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

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

Office of American Schools and Hospitals Abroad (ASHA), Bureau for Democracy, Conflict and Humanitarian Assistance (DCHA)

Funding Operating Unit(s): DCHA/ASHA Funding Account(s): Development Assistance (DA) Funding Amount: N/A Amendment Funding Date: N/A Amendment Funding

Amount:

N/A

Other Affected Unit(s): AFR, Asia, E&E, LAC, ME Lead BEO Bureau: DCHA Prepared by: DCHA/ASHA Date Prepared: November 2, 2018

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: Initial Environmental Examination Environmental Determination(s): Categorical Exclusion, Negative Determination, IEE Expiration Date: Dec 31, 2023 Additional Analyses/Reporting Required: N/A Climate Risks Identified (#): Low __2____ Moderate______ High __3____ Climate Risks Addressed (#): Low __N/A_ Moderate _N/A___ High

__N/A____

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THRESHOLD DECISION MEMO AND SUMMARY OF FINDINGS

PURPOSE AND SCOPE OF THE INITIAL ENVIRONMENTAL EXAMINATION

The purpose of the Global Office of American Schools and Hospitals Abroad (ASHA) Initial Environmental Examination (IEE)1 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. This ASHA Global IEE is comprised of a signatory Facesheet, a high-level analysis of key activities, and templates. This ASHA Global IEE fulfills the pre-obligation requirements of Title 22, Code of Federal Regulations, Part 216 (22 CFR 216) and Automated Directives System (ADS) chapters 201 and 204. The ASHA Global IEE provides the following:

a) Analysis of environmental impact and climate risk;

b) Assignment of regulatory threshold determinations and climate risk ratings; and

c) Conditions for environmental impact and climate risk management, monitoring, and reporting.

PROJECT/ACTIVITY SUMMARY

This IEE reviews three types of interventions conducted under USAID/ASHA: commodity procurement, capital improvements, and activities involving pesticides.

ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

TABLE 1. ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

Projects/Activities Recommended Environmental Threshold Decision

Recommended Climate Risk Rating

Education, training, and technical assistance, not including activities affecting the environment.

Categorical Exclusion, pursuant to 22 CFR 216.2(c)(2)

Low, as in ADS 201mal, Section 3

Procurement of commodities that do not contain hazardous materials.

Categorical Exclusion, pursuant to 22 CFR 216.2(c)(2)

Moderate, as in ADS 201mal, Section 42

Procurement of commodities to include biomedical equipment and related hazardous materials.

Negative Determination Moderate, as in ADS 201mal, Section 4

Small-scale construction and rehabilitation of facilities. Negative Determination

High, as in ADS 201mal, Section 3

Procurement, use, transport, storage, or disposal of pesticides (requires Pesticide Evaluation Report and Safer Use Action Plan

(PERSUAP)).

Negative Determination

Moderate, as in ADS 201mal, Section 4

The ASHA Global IEE was previously termed the ASHA Programmatic IEE (P-IEE)

2 As mentioned in the USAID ADS 201mal, CRM is an iterative and adaptive process, where risks and risk ratings are reconsidered as new information on either programmatic approaches or expected climate impacts becomes available. Recommended “Moderate” risk ratings may therefore be modified to either High or Low depending on the project-specific context.

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BEO-SPECIFIED CONDITIONS OF APPROVAL

The Agreement/Contract Officer’s Representative (AOR) will ensure that ASHA implementing partners (IPs) will incorporate the following nine (9) requirements (more details provided in Section 5 of this ASHA Global IEE):

Condition 1: Adhere to ASHA Global IEE and Global Construction PERSUAP3 to develop proposal application.

Condition 2: Develop Environmental Capability Statement (ECS) as part of the project proposal application.4

Condition 3: Develop EMMP and CRM for all Commodity Procurements awards.

Condition 4: Develop IEE, EMMP and CRM for all Capital Improvement awards.

Condition 5: Develop project-specific Construction SUAP for all procurement and/or use of pesticides.

Condition 6: Respond to any gaps identified in the BEO Issues Letter

Condition 7: Conduct Environmental Reporting as part of ASHA QPRs.

Condition 8: Integrate Requirements into Sub-contracts for engineering, waste management, material sourcing, etc.

Condition 9: Adhere to Partner Country Regulations.

IMPLEMENTATION

In accordance with 22 CFR 216 and Agency policy, the conditions and requirements of this document become mandatory upon approval.

3 USAID Global Construction PERSUAP (2018): https://ecd.usaid.gov/document.php?doc_id=51716.

4 ECS template is available on the ASHA Google Drive as Annex A:

https://drive.google.com/drive/folders/103ZUYH0JxuonKDUHBOCr0ShekwkwtRZD.

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USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY NAME: ASHA GLOBAL INITIAL ENVIRONMENTAL

EXAMINATION (ASHA Global IEE)

Approval: __________________________________________________ Anne Dix, Mission Director or Washington DC Equivalent

Date

Clearance: __________________________________________________ Erika J. Clesceri, Climate Integration Lead

Concurrence: __________________________________________________ Erika J. Clesceri, Bureau Environmental Officer

DISTRIBUTION:

Bureau Environmental Officers (BEOs):

● Brian Hirsch, USAID/Africa

● Will Gibson, USAID/Asia

● Mark Kamiya, USAID/Europe and Eurasia

● Diana Shannon, USAID/Latin America and the

Caribbean

● John Wilson, USAID/Middle East

● Teresa Bernhard, USAID/Economic Growth, Education and Environment

● Dennis Durbin, Global Health

Regional Environmental Advisers (REAs):

● David Kinyua, USAID/East Africa

● Aaron Brownell, USAID/Southern Africa

● Melody McNeil, USAID/West Africa

● Samantha Wapnick, USAID/West Africa for the

Sahel*

● Andrei Barannik, USAID/Central & South Asia

● Chris Dege, USAID/Southeast Asia & the Pacific

● Georgina Melendez, USAID/ Latin America & the

Caribbean

● Suzanne Ebert, USAID/Middle East

Mission Environmental Officers (MEOs):

● Asim Aziz, USAID/OAPA/Pakistan

● Yitayew Abebe, USAID/AFR/Ethiopia*

● Emmanuel Odotei, USAID/AFR/Ghana

● Abdourahmane Ndiaye, USAID/AFR/Niger

● David Kinyua, USAID/AFR/Somalia*

● Judith Muhomba, USAID/AFR/Southern & South

Africa

● Dosteus Lopa, USAID/AFR/Tanzania

● Jessica Okui, USAID/AFR/Uganda

● Mwewa Katongo, USAID/AFR/Zambia*

● Nina Kavetskaya, USAID/ASIA/Central Asian Republics*

● Monali Zeya Hazra, USAID/ASIA/India

● Shanker Khagi, USAID/ASIA/Nepal

● Khuong Tran Chinh, USAID/ASIA/Vietnam

● Marina Vardanyan, USAID/E&E/Armenia*

● Gocha Lobzhanidze, USAID/E&E/Georgia

● Joth Singh, USAID/LAC/Barbados & Eastern

Southern Caribbean

● Mary Rodriguez, USAID/LAC/El Salvador

● Regina Soto, USAID/LAC/Guatemala*

● Peter Hearne, USAID/LAC/Honduras*

● Gerald Lindo, USAID/LAC/Jamaica

● Soad Saada, USAID/ME/Egypt

● Sana Saliba, USAID/ME/Lebanon

● Fatine Bellamine, USAID/ME/Morocco

● Anan Masri, USAID/ME/West Bank/Gaza*

Climate Integration Leads (CILs):

● Judith Muhomba, USAID/AFR/Southern & South Africa

● Dosteus Mtinde Lopa, USAID/AFR/Tanzania

● Shawna Hirsch, USAID/AFR/ Uganda

● Sopheap Sreng, USAID/ASIA/Cambodia

● Chandan Samal, USAID/ASIA/India

● Asim Aziz, USAID/ASIA/Pakistan

● Chris Abrams, USAID/ASIA/ Vietnam

● Mansfield Blackwood, USAID/LAC Barbados and

Eastern Southern Caribbean

● Luis Ramos, USAID/LAC/El Salvador

● Gerald Lindo, USAID/LAC/Jamaica

● Marcela Villagra, USAID/LAC/Nicaragua

● Veronica Lee, USAID/E&E/Georgia

● Andriy Nesterenko, USAID/E&E/Ukraine

● Stuart Banashek, USAID/ME/Egypt

*Also the Climate Integration Lead (CIL)

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TABLE OF CONTENTS

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE AND SCOPE OF IEE

1.2 PROJECT/ACTIVITY OVERVIEW

1.3 PROJECT/ACTIVITY DESCRIPTION

2.0 BASELINE ENVIRONMENTAL INFORMATION

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

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL

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

AND INSTITUTIONAL STANDARDS (E.G., ISO, SCHOOL/HOSPITAL CERTIFICATIONS)

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

3.1 COMMODITY PROCUREMENT

3.1.1. ENVIRONMENTAL IMPACTS

3.1.2. CLIMATE RISKS

3.2 CAPITAL IMPROVEMENT

3.2.1. ENVIRONMENTAL IMPACTS

3.2.2. CLIMATE RISK CONSIDERATIONS

3.3 PESTICIDES

3.3.1. ENVIRONMENTAL IMPACTS

3.3.2. CLIMATE RISK CONSIDERATIONS

4.0 ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

4.1 RECOMMENDED ENVIRONMENTAL THRESHOLD DETERMINATIONS

4.1.1. CATEGORICAL EXCLUSION

4.1.2. NEGATIVE DETERMINATION

4.1.3. PRE-AWARD AND POST-AWARD EIA PROCESS

4.2 RECOMMENDED CLIMATE RISK RATINGS

4.2.1 HIGH CLIMATE RISK

4.2.2 MODERATE CLIMATE RISK RATING

4.2.2 LOW CLIMATE RISK RATING

4.3 ASHA GLOBAL IEE ENVIRONMENTAL THRESHOLD DETERMINATIONS AND CLIMATE RISK

RATINGS

4.4 CLIMATE RISK MANAGEMENT SUMMARY NARRATIVE

5.0 CONDITIONS AND MITIGATION MEASURES

5.1 PRE-AWARD

5.2 POST-AWARD

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION

7.0 REVISIONS

ANNEXES

USAID ASHA FY 2019-2023 GLOBAL IEE 6

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE AND SCOPE OF 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 interventions described herein and recommend determinations and, as appropriate, conditions, for these activities. Upon approval, these determinations, per 22 CFR 216 and specified conditions become mandatory obligations of implementation. This ASHA Global IEE also documents the results of the project/activity level Climate Risk Management (CRM) process in accordance with USAID policy (specifically, ADS 201mal).

This ASHA Global IEE establishes the overall environmental compliance process for every ASHA project implemented around the world. The ASHA Global IEE serves as a pre-award decisional document, which will be subsequently supplemented and replaced by project-specific environmental compliance and CRM documentation developed by the ASHA implementing partner (IP), including the Environmental Capability Statement (ECS) that applicants submit with their pre-award application. The ECS describes their proposed approach to integrate environmental and climate risk management systems as part of the initial project design.

Post-award compliance documentation includes the supplemental project-specific IEEs and CRM screenings, Environmental Mitigation and Monitoring Plans (EMMPs), PERSUAPs and/or and Environmental Assessments (EAs). These project-specific, post-award analytical documents describe the project-specific environmental baselines, potential environmental impacts, and environmental mitigation measures, including how mitigations will be financed and monitored. Implementing partners will be responsible for submitting compliance documents to the ASHA Agreement Officer’s Representative (AOR). If the IP has multiple similar ASHA activities, the IP may modify the existing IEE and/or EMMP to incorporate any additional impacts and mitigations required to address new activities or sites and indicate which ASHA activities are covered by the existing EMMP.

1.2 PROJECT/ACTIVITY OVERVIEW5

The Office of American Schools and Hospitals Abroad began in 1947 and was incorporated into USAID by the Foreign Assistance Act of 1961. Since its inception, USAID/ASHA has achieved a visible legacy by aiding approximately 300 institutions globally and aiding in the development of innovative and state-of-the-art schools, libraries, and medical centers in more than 80 countries. USAID/ASHA’s record of contributing to and building connections with vibrant networks of civil society institutions extends through 26 U.S. Congresses and 18 presidential administrations. USAID/ASHA currently manages a worldwide portfolio of approximately 110 awards and is an invaluable complement to USAID’s wide-ranging development work.

USAID/ASHA directly contributes to U.S. foreign policy and public diplomacy objectives by fostering strong civil society institutions and excellence in higher education and innovation. The networks of educational and medical institutions supported by USAID/ASHA offer opportunities to access quality education and health services in areas of the world where often few or none exist. USAID/ASHA has educated successive generations of global citizens and leaders, deepening their understanding of American ideas and practices. As institutions of learning, ASHA institutions provide a unique opportunity to showcase the latest approaches to integrating environmental and social impact concerns

5 Overview from https://www.usaid.gov/work-usaid/business-funding/grant-programs/american-schools-and-hospitals-abroad.

USAID ASHA FY 2019-2023 GLOBAL IEE 7

through public consultation from the development of capital improvement plans to the development of internal controls to ensure operational impacts are minimized.

1.3 PROJECT/ACTIVITY DESCRIPTION

This IEE considers three primary types of interventions financed through ASHA programs: commodity procurement, capital improvement, and activities involving pesticides.

Commodity Procurement: These involve the procurement of materials, resources, or equipment such as generators, computers, incubators, surgical instruments, furniture, and office supplies.

Commodity procurement will ultimately generate three main categories of wastes: general, medical, and other hazardous wastes. Some commodity purchases require specific considerations at installation and during operations to ensure environmental impacts on the natural environment and human health and safety (such as exposure to radiation, toxic fumes, and fire).

Capital Improvement: This involves construction, rehabilitation, or renovation. This may include new construction, expansion, rehabilitation, or retrofit of buildings and facilities (e.g., hospitals, schools, clinics, centers, and libraries).

Pesticides: Any activity involving the procurement, transport, storage, use, or disposal of pesticides.

Examples include land treatment for termite control during facility construction and use of a chemical product for rodent control during facility operation.

USAID ASHA FY 2019-2023 GLOBAL IEE 8

2.0 BASELINE ENVIRONMENTAL INFORMATION

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT,

PHYSICAL, CLIMATE, SOCIAL)

Projects under ASHA may take place in any USAID Mission or country covered by a USAID Regional Mission. It is anticipated that ASHA projects will be carried out in varying urban and rural ecosystems and in areas that are beset by poverty and/or are recovering from damage and destruction caused by military operations and insurgency activities. Because the specific characteristics and locations of these projects are unknown and expected to vary significantly, it is not possible to analyze the baseline environmental conditions for all locations affected.

Using guidance provided in this ASHA Global IEE, all ASHA IPs will be required to develop project site-specific IEEs (Supplemental IEEs) and/or EMMPs that addresses necessary mitigations to address the negative determinations and CRM risks identified in Table 1 (p.2) for the types of activities identified on p.7.

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER

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

POLICIES, AND REGULATIONS, AND INSTITUTIONAL STANDARDS (E.G., ISO,

SCHOOL/HOSPITAL CERTIFICATIONS)

Implementation of award projects must, in all cases, adhere to applicable partner country environmental laws and best practices. For projects requiring supplemental IEEs,6 the implementing partner (IP) must include descriptions of all relevant environmental policies and procedures. IPs may source partner-country environmental policy and regulatory framework information from past IEEs that are publicly available at the USAID Environmental Compliance Database: https://ecd.usaid.gov/. However, the IP must ensure they capture any additional relevant policies/regulations, including any that have been enacted since the past IEEs were developed. They cannot assume that past IEEs would have all the most current and applicable information.

It is quite common for many of the ASHA grant holding institutions to already in possession or to be actively seeking various international sustainability certifications. If applicable, IPs may provide information on any institutional standards and certifications the institution as a whole holds or is working towards. This can include Institutional Organization for Standardization (ISO) certifications, or green building certifications, including Leadership in Energy and Environmental Design (LEED), Building Research Establishment Environmental Assessment Method (BREEAM) and Green Star, or other standards specific to educational and healthcare institutions.

2.2.1 APPLICABLE AND APPROPRIATE USG AND INTERNATIONAL STANDARDS

AVAILABLE FOR CONSULTATION

To develop project-specific analyses, ASHA IPs are expected to first draw from existing USAID or other country-level environmental analyses, including 118/119 Biodiversity and Tropical Forestry Assessments, the International Union for Conservation of Nature, the UN Environment Knowledge Repository, and the International Association for Impact Assessment. The USAID Mission Environmental Officer (MEO) may also be consulted to provide additional resources or assistance.

ASHA IPs are also expected to refer to the following resources when developing analyses that evaluate climate risk considerations: The USAID ClimateLinks website provides country- and region-specific

6 Supplemental IEEs can also be called Awardee IEEs

USAID ASHA FY 2019-2023 GLOBAL IEE 9

profiles on climate vulnerability, risk and/or adaptation. The USAID Mission Climate Integration Lead (CIL) may also be consulted to provide additional resources.

USAID ASHA FY 2019-2023 GLOBAL IEE 10

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

3.1 COMMODITY PROCUREMENT

Without proper management, commodity procurement poses potential risks to human health and/or the environment, particularly in relation to the resulting generation and disposal of wastes. This ASHA Global IEE identifies three main categories of wastes resulting from commodity procurement, each with an associated risk:

● General wastes (X). General waste is similar to most domestic waste and includes plastic and paper packaging. Most healthcare wastes fit into this category, which does not require special handling.

● Medical wastes (M). Medical waste refers to hazardous wastes that are infectious, chemical, or radioactive wastes generated by healthcare activities and spans a broad range of materials including diagnostic samples, blood, used sharps (needles, scalpels, etc.), pathological or anatomical wastes, chemicals, pharmaceuticals, and radioactive materials.7

● Other hazardous wastes (H). Other hazardous waste is waste that is not classified as medical waste but that requires special handling and disposal, generally due to the presence of heavy metals or other toxic materials. Examples of hazardous commodities include batteries, fluorescent light bulbs, and computer monitors.

In order to screen for these risks, the commodities are classified as “H” for Hazardous, “M” for Biomedical, and “X” for neither hazardous nor biomedical.

TABLE 2. CLASSIFICATION OF WASTE STREAMS FROM EXAMPLE COMMODITIES

General (X) Medical waste (M) Other hazardous waste (H)

Furniture (chairs, tables, desks) Incubator Generator

Journals and magazines Surgical Instrument set Desktop computer/Laptop

Office Supplies Defibrillator E-book reader device/Tablets

Books Endoscope Solar panels, batteries, inverter

OR table Electrosurgical unit Chemistry Laboratory Kit

Office shelves CT Scanner TV and computer monitors

Data storage Ventilator Microscope

3.1.1. ENVIRONMENTAL IMPACTS

The environmental impacts associated with the procurement, transport, use, storage, and disposal of materials, resources, or equipment containing hazardous materials or generating hazardous wastes include 1) contamination of water, air, and soil, 2) increase in disease transmission, and/or 3) exposure of workers or local population to harmful, toxic, and carcinogenic materials and wastes.

7 WHO, 2015 http://www.who.int/topics/medical_waste/en

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Waste management is a major issue for many of the urban and peri-urban educational center activities, meetings, conferences, and trainings funded by ASHA. Many of these centers have sub-standard solid waste management systems, which can contribute to the adverse impacts described above and adversely impact both public health and economic development.

● General waste management General waste is comparable to domestic waste and is usually called “non-hazardous” waste. It comes mostly from office, kitchen and housekeeping activities and may also include packaging waste and waste generated during maintenance of commodities and infrastructure. It does not require special handling.

● Contamination and disease transmission from medical waste Some commodities likely to be procured by ASHA-funded projects, such as ventilators, surgical equipment, and endoscopy probes, have the potential to generate medical waste during use, such as sharps, pathological waste, radioactive or cytotoxic waste. Other commodities may require the use of hazardous chemicals during their operation and maintenance, such as halogenated solvents and formaldehyde used in diagnostic and laboratory work or to clean/disinfect certain equipment. Improper handling and disposal of these waste streams may adversely affect both human health and the environment. Poor management of healthcare wastes often occurs in small-scale facilities in developing countries where ASHA supports projects and where it is common practice to dispose of healthcare wastes along with other solid wastes or to bury the medical wastes without treatment. Disease transmission can occur due to inadequate treatment and disposal of medical waste and impact patients, healthcare workers and staff, visitors, waste handlers, and the general public.

Inadequate disposal of chemical and pharmaceutical waste carries many risks. Unwanted pharmaceuticals and chemicals are often dumped into septic tanks or latrines. Disposal in unlined landfills or pits could create a hazardous leachate that may contaminate ground and surface water, affecting human and environmental health.

Inadequate incineration of medical wastes has many potential risks. USAID recognizes and supports the sound use of medical waste incinerators; however, it is important to emphasize that medical waste management requires strong technical oversight to ensure safe and effective treatment. Large volumes of medical wastes are very difficult to properly treat via incineration even with robust levels of staff training and funding and access to routine maintenance. These resources are often lacking in many situations in which ASHA operates, which often face challenges due to overwhelming demand for disposal due to urban or densely populated settings and a lack of maintenance for aging infrastructure. Improper incineration of hospital waste is associated with a variety of environmental and public health threats. It is linked to the release of heavy metals, acid gases, and particulates into the air and, ultimately, into bodies of water. If the ash is not disposed of properly then it, too, poses a threat to air quality and water supply.

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● Contamination from other hazardous waste (e.g., electronic waste (e-waste), heavy metals) Some commodities likely to be procured under ASHA-funded projects have the potential to generate other hazardous waste, including heavy metals. Examples include:

● Electronic equipment, such as computers, whose components (e.g., monitors, printed circuit boards) contain lead and mercury

● Energy-saving lighting (e.g., mercury in fluorescent light bulbs; lead, arsenic, nickel and other potentially dangerous and carcinogenic substances in LED light bulbs)8

● Non-digital X-ray and other radiography equipment require the use of X-ray films, which contain heavy metals such as silver thiosulfate

These heavy metals can cause significant environmental and health impacts if improperly disposed of, ranging from damage to the nervous system and kidneys, to water and land contamination from inadequately disposing of such equipment. Adverse impacts may affect workers exposed to heavy metals during handling and disposal of these commodities, requiring adequate mitigation measures.

These wastes require segregation before treatment and use of treatment techniques appropriate for each of the different waste streams. It has previously been observed in ASHA programs that anaerobic digestion has been used as alternatives for hazardous waste treatment. And while such innovative measures are commendable, proper measures must be taken to ensure that these treatment techniques are effective and efficient for the specific waste streams they intend to address. Anaerobic digestion (while highly effective for disposal of certain types of waste and an innovative technology that generates biogas) can be disrupted by adding various chemical waste streams to the mix, resulting in incomplete waste treatment, damage to the biodigester, and release of toxic effluents. Therefore, adequate segregation of waste streams and appropriate selection of treatment technique is necessary for effective management and disposal of hazardous waste streams.

3.1.2. CLIMATE RISKS

Current and future climate conditions can affect the ability to procure, deliver, use, maintain and store commodities procured under these awards.

The nature and degree of climate risk for a given commodity depends on the characteristics of the commodity (e.g., usable life span, required storage conditions, intended purpose/use), and, perhaps most importantly, the geography and location(s) where the commodity will be delivered and used. One hospital site may face a much greater risk of flash flooding, high winds, and/or storm surge linked to rising sea levels than a second site due to their respective locations and elevations within a country. It is critical to understand the climate conditions (both historical and future projections, to the degree possible) for relevant locations in the life-span of a commodity.

Example climate conditions which might affect commodities:

● High temperatures and/or humidity could affect the integrity or longevity of the commodity (e.g., temperature/moisture sensitive lab or medical equipment and pharmaceuticals) and the structure in which it is stored and used.

8 Scientific American, 2012 http://www.scientificamerican.com/article/led-lightbulb-concerns/.

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● Extreme climate events (e.g., storms, flash floods, high wind events) could damage a commodity and the structure in which it is stored and used; affect access routes and limit the ability to transport the commodity; and damage disposal sites (e.g., incinerators, landfills) and expose improperly-disposed of materials.

● Sea-level rise, increased erosion and more intense storm surges, could damage storage sites, access routes, and disposal sites.

● Drought conditions and changing rainfall patterns could affect water availability, which may impact the ability to use or maintain the commodity.

3.2 CAPITAL IMPROVEMENT

3.2.1. ENVIRONMENTAL IMPACTS

Construction, rehabilitation, and renovation activities have the potential to cause direct and indirect adverse environmental impacts.

Direct impacts may include habitat loss when land is converted for use as a project site or the introduction of an invasive species when replanting vegetation around construction sites. Indirect impacts may include induced changes in the environment, population, and/or use of land and environmental resources arising from an influx of construction workers, the development of worker camps, and increased camp staff interactions with surrounding resources and populations (e.g., habitat loss or changes to habitat due to noise and/or light pollution, deforestation for campfires, traffic congestion, spread of disease including Sexually Transmitted Infections, and increase in sexual assaults).

Examples of potential impacts associated with construction or renovation are provided below; however, the below examples are not exhaustive. Environmental impacts associated with capital improvements are often temporary and end when the construction activity is complete; however, some impacts may occur or continue after construction.

● Air pollution Earthwork activities that disturb soil and generate dust create ambient air pollution. Vehicles disturbing and transporting soil, products, materials, and fuels in and out of construction areas generate dust and emit toxic gases, such as SOx, NOx, CO, CO2, and CxHy. Air pollution includes the generation of dust, acidic gases and carbon monoxide as detailed below:

● Dust Dust is a group of inorganic and organic small-sized substances existing in suspended form, settlement form, or vapor gas, smoke, and foggy form in the air. Dust is mainly larger than 5 micrometers. When people breathe dusty air, the dust is trapped in the bronchus by vibrissae.

Smaller particles may enter the alveolus, which can cause lung fibrosis, coughing, chest soreness, and/or infection.

● Acidic gases Acidic gasses like Sulfur Oxides and Nitrogen Oxides combine with oxygen in the air, and then with moisture in the air to form acidic steam that can irritate mucous membranes. A high concentration of acidic gases in the air can damage tree leaves after a couple hours of exposure.

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● Carbon monoxide Carbon monoxide is a poisonous gas that produces toxic carboxyhemoglobin when it comes in contact with hemoglobin, which decreases the transference of oxygen in blood in human tissue.

● Aerosols and Refrigerants Capital improvements and commodities may require the use of refrigerants or aerosols that could impact ozone layer. They could also increase the overall risk of fire, radiation or chemical emissions from the facility.

● Noise pollution Noise pollution can affect worker health and may lead to reduction of work capacity. Contact with loud noises causes the body to become tired and produces headaches, dizziness, and more frequent labor accidents. Contact with noise for long periods of time can easily cause occupational deafness. Noise pollution can impact nearby communities by altering social routines and negatively impacting social services (e.g., disrupt classroom activities, disturb patients in hospital).

● Soil erosion and sedimentation of surface waters Removal of natural land cover, excavation or extraction of construction materials or resources for facility operation (e.g., sourcing of wood resources from a degraded forest to heating), and other related activities can result in soil erosion. Soil erosion increases flood potential and can lead to sedimentation in receiving waters. Sedimentation may reduce the capacity of ponds and reservoirs, further increasing flood potential, or it may substantially alter aquatic ecosystems by changing streambed, lakebed, and estuary conditions.

● Surface and groundwater contamination Toxic materials are often used in construction or building maintenance. Examples include solvents, paints, vehicle maintenance fluids (oil, coolant), and diesel fuel. If these are inappropriately used, stored, or disposed of, they may contaminate ground or surface water supplies. This may harm the health of the local community, as well as the populations living down gradient and downstream. Aquatic and terrestrial ecosystems may also be damaged. (See description of impacts from wastewater and sanitation facilities in next section).

● Small-scale wastewater and sanitation systems Potential adverse impacts from improperly implemented wastewater and sanitation activities include: 1) increased human health risks from contamination of surface water, groundwater, soil, and food by excreta, chemicals, and pathogens (e.g., cholera, arsenic poisoning); 2) increased incidence of vector-borne diseases (e.g., malaria); and 3) ecological harm from degradation of stream, lake, estuarine, and marine water quality and degradation of land habitats. Moreover, foul odors from wastewater degrade the overall aesthetic environment and can potentially degrade groundwater via with the aforementioned discharge components.

These risks are often increased when the wastewater originates from a hospital, as it often contains high concentrations of organic and inorganic chemicals, detergents, and pathogenic bacteria from examination and treatment rooms, laboratories and test labs, and restrooms and washing rooms for patients and staff, among other sources.

● Potable water quantity and quality assurance Insufficient potable water quantity may lead to the consumption of water with poor quality, leading to the spread of waterborne diseases such as diarrheal diseases, typhoid fever, cholera, dysentery, salmonellosis and botulism. It is therefore important to evaluate water needs and

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water availability, with special consideration for the expansion in planned activities (e.g., the influx of more students or patients as a result of new construction) as well as climate projections and extreme weather events that may add stress to existing water sources.

The USAID Africa (AFR) Bureau has recently released guidance and a template for developing a Water Quality Assurance Plan (WQAP, also see Annex F). USAID emphasizes analysis of the following eight parameters, at a minimum, given their potential for significant health impacts:

arsenic, fecal coliforms, fluoride, nitrate, electro-conductivity, total dissolved solids (TDS), pH and turbidity.9The consumption of arsenic at high concentrations can lead to death, while long-term exposure at lower concentrations through drinking water sources can lead to a severe chronic illness called arsenicosis. Fecal coliform, especially Escherichia coli (E. coli), is the most common waterborne pathogen linked to diarrheal diseases. According to the World Health Organization, diarrheal diseases cause 1.5 million deaths annually, and approximately, 58% of these deaths are attributable to unsafe water supply, sanitation facilities, and hygiene practices.

The following table, extracted from the USAID AFR Bureau WQAP template (p. 10-11) outlines USEPA and WHO limits for these eight minimum parameters. The implementing partner will be required to also add host country regulations limits and frequencies for these parameters.

Where there are discrepancies between the three guidance limits, the most stringent limit must be respected.

Parameter

USEPA Guidance WHO Guidance

Limit Frequency Parameter Frequency

Arsenic 0.01 mg/l quarterly 0.01 mg/l Not Stated

Fecal Coliform 00/100 ml quarterly 00/100 ml Not Stated

Fluoride 4.0 mg/l Not Stated 1.5 mg/l Not Stated

Nitrate 10 mg/l Not stated 50 mg/l Not Stated

Electrical Conductivity (EC) 1600 μS/cm Not Stated Not Stated Not Stated

Total Dissolvable Solids (TDS) 500 mg/l Not Stated 1000 mg/l Not Stated pH 6.5 - 8.5 S.U. Not Stated Not Stated Not Stated

Turbidity 5 NTU Not Stated Not Stated Not Stated

9 Analysis of these parameters — at minimum — is required by USAID AFR Bureau’s recently released template and guidance for developing a Water Quality Assurance Plan (WQAP).

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● Solid waste management The typical solid waste stream for capital improvement projects will contain construction and demolition debris, general operational wastes (organics and recyclables), as well as special wastes (household hazardous, healthcare, and industrial waste). Most adverse environmental impacts from solid waste management are rooted in inadequate or incomplete collection and recovery of recyclable or reusable wastes and improper disposal of hazardous wastes due to inappropriate siting, design, and management of dumps and landfills. The renovation of old buildings may also generate asbestos waste, polychlorinated biphenyls (PCBs) waste (found in caulk, transformers, fluorescent light ballasts, etc.), heavy metal waste (often found in lighting systems and flooring), and lead-contaminated dust. Improper solid waste management activities can lead to the following:

● Increased disease contraction and transmission. Rotting organic materials pose great public health risks, such as breeding grounds for disease vectors. Human and/or animal excreta or healthcare wastes in the waste stream pose increased risk of disease transmission. Waste handlers and waste pickers are especially vulnerable to these risks and may also become vectors by contracting and transmitting diseases. (See the discussion on healthcare wastes below). Asbestos or lead containing materials also have the potential to pose serious health risks. Asbestos is a known contributor to lung cancer and respiratory problems, such as mesothelioma and asbestosis.

● Contaminated ground and surface water. Solid waste streams can bleed toxic materials and pathogenic organisms into the leachate of dumps and landfills (leachate is the liquid discharge of dumps and landfills; it is composed of rotted organic waste, liquid wastes, infiltrated rainwater, and extracts of soluble material). If the landfill is unlined, this runoff can contaminate ground or surface water, depending on the drainage system and the composition of the underlying soils. Many toxic materials, once placed in the general solid waste stream, can be treated or removed only with expensive advanced technologies. These are generally not feasible in countries where ASHA implementing partners work.

● Increased greenhouse gas emissions and other air pollutants. When organic wastes are disposed of in deep dumps or landfills, they undergo anaerobic degradation and become significant sources of methane, a gas with 21-25 times the effect that carbon dioxide has in trapping heat in the atmosphere. Garbage is often burned in residential areas and in landfills to reduce volume and uncover metals. Burning creates thick smoke that contains carbon monoxide, soot, and nitrogen oxide, all of which are hazardous to human health and degrades urban air quality. Combustion of polyvinyl chlorides (PVCs) generates highly carcinogenic dioxins.

● Damaged ecosystems. When solid waste is dumped into rivers or streams it can alter aquatic habitats and harm native plants and animals. The high nutrient content in organic wastes can deplete dissolved oxygen in water bodies, denying oxygen to fish and other aquatic life forms. Solids can cause sedimentation and change stream flow and bottom habitat. Dumps or landfills sited in sensitive ecosystems may destroy or significantly damage these valuable natural resources and the services they provide.

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● Injury to people and property. In locations where shanty towns or slums exist near open dumps or near badly designed or operated landfills, landslides or fires can destroy homes and injure or kill residents. The accumulation of waste along streets may present physical hazards, clog drains, and cause localized flooding.

● Discouraged tourism and other business. The unpleasant odor and unattractive appearance of piles of uncollected solid waste along streets and in fields, forests, and other natural areas can discourage tourism and the establishment and/or maintenance of businesses.

● Construction Material Sourcing Implementing partners should pay close attention to the sourcing of materials used in construction and renovation activities. For example, borrow pits may be located in stream or river beds or endanger other infrastructure; timber may be sourced illegally or treated with toxic chemicals offsite; materials used could contain lead or asbestos;

arsenic and/or lead could be encountered during renovation, endangering the health of facility users and construction workers.

● Construction Health and Safety

Implementing partners should ensure that construction firms are adhering to strict standards of construction safety for workers and people nearby. For example, the need to restrict access to or fence off certain dangerous areas, and for clear signage set up to warn people of hazards. Worker must also wear adequate Personal Protection Equipment (helmets, dust masks, gloves, etc.). Environmental noise should be managed and kept to a minimum and at reasonable hours. Transport of materials on/off site should be carefully managed to avoid endangering people nearby. Runoff should be contained. Alternate pedestrian walkways should be installed. Paint and other materials with toxic fumes should be handled with appropriate ventilation and safety.

3.2.2. CLIMATE RISK CONSIDERATIONS

Construction activities and the longevity of the finished products may experience significant impacts due to climate stressors. Heat waves, wildfires, dust storms, and other climate-related impacts may affect construction timelines and workers. Changes in the frequency or severity of extreme rainfall events and flooding, as well as increasing maximum temperatures can affect the longevity/usable life of structures and facilities.

There is an additional layer of consideration with respect to climate risks for construction siting decisions. Changing climate conditions and resulting sea level rise can significantly affect the suitability of certain potential sites for new construction and rehabilitation of existing buildings. For example, some geographic locations may face a much greater risk of impacts from storm surges and flooding, as well as associated landslides and erosion.10

10 For further details on considering climate risks for small-scale construction, see the USAID Climate Risk Screening and Management Tool: Annex on Infrastructure, Construction, and Energy as well as the USAID technical report on Addressing Climate Change Impacts on Infrastructure.

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3.3 PESTICIDES

3.3.1. ENVIRONMENTAL IMPACTS

Pesticides are any substance or mixture of substances that prevent, destroy, repel or mitigate any pest.

They can also be used as a plant regulator, defoliant or desiccant, or nitrogen stabilizer. As such pesticides include fungicides, herbicides and other substances used to control any pest or weed.

Many ASHA projects treat soil and timber with pesticides to control pests such as termites, wood borers, rodents and fungi. Pesticides have significant adverse impacts that users and the general population are often unaware of when handling them.

Sometimes, toxic chemicals such as creosote and chromated copper arsenate (CCA) are used to treat wood. However, creosote is a known carcinogen, and as such as been rejected from use by USAID-financed activities. Likewise, the use of CCA for indoor residential use was discontinued by the EPA in 2004 by manufacturers and contact with CCA-treated wood may overtime lead to a risk of exposure to arsenic content. The USAID Global Construction PERSUAP11 (or Global Construction PERSUAP) provides more guidance on recommended pesticide active ingredients rejected substances for termite and rodent control ASHA construction-related activities.

Most pesticides impact not only their target species, but also non-intended species, air, water, bottom sediments, and the food humans consume. Pesticides can contaminate land and water when used or discarded improperly. Humans and other animals who ingest, inhale, or come in dermal contact with pesticides may suffer side-effects ranging from mild skin irritation to birth defects, tumors, genetic changes, blood and nerve disorders, endocrine disruption, and even coma or death.

Inappropriate use of pesticides can also increase pest resistance and kill the natural enemies of pests, which is counterproductive to the pesticides’ original purpose. Some pesticides contribute to climate change and the depletion of the ozone layer.

3.3.2. CLIMATE RISK CONSIDERATIONS

Climate change may affect pest behavior and distribution, intensity of pest infestations and may decrease the effectiveness of pesticides. For example, termites prefer habitats that are well drained and are not too dry or too wet. Changing rainfall and temperature patterns due to climate change could impact geographic range and size of colonies, therefore influencing the distribution and concentration of termiticide use.12 Termite damage has been observed to be of greater intensity during periods of drought or excessive rainfall in contrast to periods of regular precipitation.13 Thus, if climate change results in extremes such as drought and heavy rainfall, damage from termites may increase.

While global average temperatures are expected to continue to rise, rainfall patterns are expected to change differently depending on geography. For example, climate projections may include increasing temperatures, an increase in extreme weather with intense precipitation and resultant flooding, and longer dry periods (among other potential climate stressors).

Although there is uncertainty regarding the degree to which such changes will occur and what their magnitude and severity may ultimately be, climate change could lead to increased surface runoff, 11 USAID Global Construction PERSUAP (2019): https://ecd.usaid.gov/document.php?doc_id=51716 12 Carnegie Science, 2010 https://carnegiescience.edu/news/termites-foretell-climate-change-africa%E2%80%99s-savannas 13 Ahmed, B.M., P.O.Y. Nkunika, G.W. Sileshi, J.R.J. French, P. Nyeko and S. Jain. 2011. Potential Impact of Climate Change on Termite Distribution in Africa. British Journal of Environment and Climate Change, 1(4): pp. 172-189. Avalable at:

http://www.journalrepository.org/media/journals/BJECC_10/2011/Sep/1317149951-Ahmedetal_2011BJECC561.pdf

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increased soil percolation/infiltration and an increased threat from termites. Considering future climate scenarios is relevant for determining when and where to use termiticide.

While evidence is largely lacking about how climate change will impact distribution of rodents, there is concern that increases in temperatures and rainfall will impact rodent distribution and the potential exposure of populations to zoonotic diseases. Studies suggest that some climate change scenarios could lead to an increase in rodent populations in temperate regions, potentially increasing the risk of disease transmission, particularly in urban areas.14

Climate change may impact the spread of pesticides through air, land, and water. For example, more frequent and intense storms could lead to flushing of pesticides into surface and ground water resources.

14 European Centre for Disease Prevention and Control, 2019 https://ecdc.europa.eu/en/climate-change/climate-change-europe/rodent-borne-diseases.

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4.0 ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK

RATINGS

USAID’s environmental impact assessment (EIA) process evaluates the reasonably foreseeable direct, indirect, and cumulative adverse impacts of a proposed project and its activities on the environment and of the environment on the project. This analysis results in environmental threshold determinations that document the Agency’s decision as to whether an action will have a significant adverse impact on the environment and what, if any, additional environmental analyses and mitigation and monitoring measures are required. Environmental threshold determinations are documented in this ASHA Global IEE and, for some intervention types, will be refined by supplemental project-specific IEEs or EAs.

This EIA process occurs in parallel to the process of screening for and addressing climate risks.

Effectively limiting risks posed by climate change requires understanding and mitigating environmental impacts. Landscapes that have become increasingly degraded due to years of poor land management are likely to have exacerbated climate risks, for instance. While USAID and IPs cannot control climate variability, it is possible and a priority to help communities better manage their land, air, and water in order to reduce risk. USAID requires application of the climate risk management (CRM) process to assess, plan for, and document the risks affecting each activity and to limit those risks and identify opportunities for improved development outcomes. ADS Mandatory Reference 201mal15 describes the CRM process and requirements, including rating activities as Low, Moderate, or High Climate Risk.

4.1 RECOMMENDED ENVIRONMENTAL THRESHOLD DETERMINATIONS

This section describes the environmental threshold determinations and identifies the recommended threshold determinations for ASHA activities based on the anticipated likelihood and severity of environmental impacts.

4.1.1. CATEGORICAL EXCLUSION

A Categorical Exclusion, pursuant to 22 CFR 216.2(c)(2), is recommended for activities that will not have an effect on the environment and belong to a class of actions set forth in 22 CFR 216.2(c)(2). A Categorical Exclusion is recommended for the following ASHA activities:

● education, training, and…