Attachment 6 - LAC-IEE-20-49 ETD.pdf

INITIAL ENVIRONMENTAL EXAMINATION

PROJECT DATA

Project Name: Government of Honduras National-level Public

Administration is more Transparent and Accountable –DO3

Geographic Location(s) (Country/Region): Honduras Amendment (Yes/No), if Yes indicate # (1) No Implementation Start/End Date (FY or M/D/Y):

May 30th, 2020 - September 30th, 2026

If Amended, specify New End Date: N/A Solicitation/Contract/Award Number(s): N/A Implementing Partner(s): N/A Bureau Tracking ID: LAC-IEE-20-49 Tracking ID of Related RCE/IEE (if any): LAC-IEE-17-22 Tracking ID of Other, Related Analyses:

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

USAID Honduras

Other Affected Operating Unit(s): None Lead BEO Bureau: LAC Funding Account(s) (if available): N/A Original Funding Amount: $60,000,000 If Amended, specify funding amount: N/A If Amended, specify new funding total:

N/A

Prepared by: Sofia Mendez Date Prepared: March 2020

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: ☒Environmental

Examination ☐Deferral

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

IEE Expiration Date (if applicable): September 30th, 2025 Additional Analyses/Reporting Required:

N/A

Climate Risks Identified (#): Low: 6 Moderate: 2 High: 0 Climate Risks Addressed (#): Low 6 Moderate: 2 High 0

THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS

PROJECT SUMMARY

The USAID/Honduras Development Objective 3 (DO3) Project seeks to support the Government of Honduras (GOH) institutions in managing public resources with more transparency and accountability. In this regard, the Project will focus on strengthening national and local-level institutions and accountability efforts to address corruption and impunity – with envisioned support from both government institutions (supply side) as well as civil society and private sector (demand side). DO3 will focus on supporting actions to improve the quality of public information, increase citizens’ rights to public archives, support public service ethics, develop a more transparent and merit-based civil service, reduce corruption and impunity, promote more efficient and effective public financial management by supporting citizen budget empowerment; and support a more efficient Justice System.

This Initial Environmental Examination Document (IEE) document purpose is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID intervention described herein. The document also recommends determinations and, as appropriate, conditions, for these activities and their actions, in accordance with Title 22, Code of Federal Regulations, Part 216.

The IEE includes three activities included in the LAC-IEE-17-22, and incorporates two new activities as defined by the DO3 Team. This IEE replaces LAC-IEE-17-22 and the earlier IEEs entirely. New COVID-19 related activities are to be included in a supplemental IEE prepared by the Mission.

ENVIRONMENTAL DETERMINATIONS

Upon approval of this document, the determinations become affirmed, per Agency regulations

(22 CFR 216).

TABLE I: ENVIRONMENTAL DETERMINATIONS

Activities Categorical

Exclusion Citation (if applicable)

Negative Determin ation

Positive Determination

Deferral

Action Type 1: Provide specialized technical assistance to enhance organizational capacity

22 CFR 216.2 (c)(2)(i) ☐ ☐ ☐

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

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

Activities: CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

Action Type 2: Facilitate and strengthen multi-stakeholder coalitions to improve transparency and deter corruption.

Activities: CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

22 CFR 216.2 (c)(2) (i) and (iii)

Action Type 3: Provide training and other capacity building actions to GOH and non-governmental actors to deter corruption.

Activities: CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

22 CFR 216.2 (c)(2)(i) ☐ ☐ ☐

Action Type 4: Support studies, analysis and other academic research workshops and meetings aimed at generating information to monitor anti-corruption practices.

Activities: CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

22 CFR 216.2 (c)(2) (iii) ☐ ☐ ☐

Action Type 5: Small-scale (less than 1000 m2) refurbishing and maintenance of existing structures.

Activities: CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity.

Action Type 6.a.: Sub-awards would support training, technical assistance, planning, and studies.

Activities: FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections

22 CFR 216.2 (c)(2)(i) and (iii)

Action Type 6.b.: Sub-awards may be used for small-scale (less than 1000 m2) refurbishing of existing structures.

Activities: FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections

Action Type 6.c: Sub-awards may provide basic equipment such as computers, printers etc.

Activities: FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections

CLIMATE RISK MANAGEMENT

In accordance with Executive Order 13677 on Climate-Resilient International Development, as of September, 2016, all USAID projects and activities require being managed for climate risks. The Climate Risk Management (CRM) process was undertaken and from this the Mission Environmental Officer and Climate Integration Lead determined that the climate risk is low for those activities within the DO3 PAD as described in section 1.3; except for the small-scale refurbishing actions for which the risk is considered moderate. The low climate risk indicates climate change is unlikely to materially impact achievement or sustainability of project or activity outcomes. The moderate climate indicates that the activity will need to incorporate actions to mitigate risk. The “Climate Risk Screening and Management Tool for Project ” is included as Annex 1.

BEO SPECIFIED CONDITIONS OF APPROVAL

None

IMPLEMENTATION

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

USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

PROJECT NAME: Government of Honduras national-level public administration is more transparent and accountable –DO3

Bureau Tracking ID: LAC-IEE-20-49

Approval:

Andrew McKim, Acting Mission Director Date

Clearance: Cleared by- email 4.29.2020 Michelle Linder, DG Office Chief Date

Clearance: Cleared by e-mail 5.1.2020 Maria Gabriela Rivera, DOTL3 Date

Clearance: Cleared by e-mail 5.5.2020 Peter Hearne, Mission Environmental Officer and Climate Integration Lead

Date

Clearance: Cleared by e-mail 6.9.2020 Michelle Dworkin, Program Officer Date

Clearance: Cleared by e-mail 6.17.2020 Andrew McKim, Acting Deputy Mission Director Date

Clearance: Cleared by e-mail 5.8.2020 Jeanne Choquehuanca, Interim- Regional Environmental Advisor Date

Concurrence:

Diana Shannon, Bureau Environmental Officer Date

DISTRIBUTION: MISSION PROJECT STAFF

Andrew McKim

Digitally signed by Andrew McKim Date: 2020.07.16 08:55:03 -06'00'

Table of Content

INITIAL ENVIRONMENTAL EXAMINATION

Project Data 1 Organizational/Administrative Data 1 Environmental Compliance Review Data 1

THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS 1

PROJECT SUMMARY 2

TABLE I: ENVIRONMENTAL DETERMINATIONS 2

CLIMATE RISK MANAGEMENT 4

BEO SPECIFIED CONDITIONS OF APPROVAL 5

IMPLEMENTATION 5

USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION 6

DISTRIBUTION: 6

Table of Content 7

1.0 PROJECT DESCRIPTION 9

1.1 PURPOSE OF THE IEE 9

1.2 PROJECT OVERVIEW 9

1.3 PROJECT DESCRIPTION 10

TABLE II: DO3 ACTIVITY DESCRIPTION 12

2.0 BASELINE ENVIRONMENTAL INFORMATION 14

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT(Environment, Physical, Climate, Social, Threatened and Endangered Species) 16

Physical and Climate 15 Social 15

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER

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

POLICIES, AND REGULATIONS 16

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK 16

TABLE III: DO3 Activity Potential Risks and Mitigation Measures 16

4.0 ENVIRONMENTAL DETERMINATIONS 20

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS 20

TABLE IV: ENVIRONMENTAL DETERMINATIONS 20

4.2 CLIMATE RISK MANAGEMENT 22

5.0 CONDITIONS AND MITIGATION MEASURES 22

5.1 CONDITIONS 22

5.1.1 During Pre-Award: 22

5.1.2 During Post-Award: 22

5.2 AGENCY CONDITIONS 24

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION 25

7.0 REVISIONS 26

ATTACHMENTS: 26

Annex 1: Climate Risk Management Summary Table for Projects 26 Annex 2: EMMP Template 26

1.0 PROJECT DESCRIPTION

1.1 PURPOSE OF THE IEE

The purpose of this Initial Environmental Examination Document (IEE) for Honduras’ Development Objective 3 (DO3) activities is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID intervention described herein. The document also recommends determinations and, as appropriate, conditions, for these activities and their actions, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216). The DO3 team is planning to incorporate two new activities in their “Government of Honduras national-level public administration is more transparent and accountable” Project Appraisal Document (PAD) further referred to as “the Project” or “DO3”. This IEE provides the environmental analysis of these activities and their actions in accordance with the 22 CFR 216.

The IEE includes three activities included in the LAC-IEE-17-22, and incorporates two new activities as defined by the DO3 Team. This IEE replaces LAC-IEE-17-22 and the earlier IEEs entirely.

COVID-19 related new activities, and specific actions not included in the LAC-IEE-20-37 Programmatic Initial Environmental Examination Document (PIEE) shall be included in the USAID/Honduras Mission Supplemental Initial Environment Examination Document (SIIE) document.

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

Upon approval, these determinations become affirmed, and specified conditions become mandatory obligations of implementation. This IEE also documents the results of the Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

1.2 PROJECT OVERVIEW

The Total Estimated Cost (TEC) for the DO3 Project is $60,000,000. The Project seeks to support Government of Honduras (GOH) institutions in managing public resources with more transparency and accountability. In this regard, the Project will focus on strengthening national and local-level institutions and accountability efforts to address corruption and impunity – with envisioned support to both government institutions (supply side) as well as civil society and private sector (demand side). DO3 will focus on supporting actions to improve the quality of public information, increase citizens’ rights to public archives, support public service ethics, develop a more transparent and merit-based civil service, reduce corruption and impunity, promote more efficient and effective public financial management by supporting citizen budget empowerment; and support a more efficient Justice System.

https://www.usaid.gov/our_work/environment/compliance/22cfr216 https://www.usaid.gov/our_work/environment/compliance/22cfr216 https://www.usaid.gov/ads/policy/200/201mal

This new IEE (LAC-IEE-20-49) will absorb activities covered by LAC-IEE-17-22 (National Anti-corruption council (CNA), Fiscal Transparency Activity, and Civil Society and Media), as well as their threshold decisions. The DO3 team revised the PAD in early 2019 and determined to include new activities into the Project to achieve its goal. This effort was paused due to suspension of funds instructed by the Secretary of State in March 2019. The Mission has updated its budget and has determined to include two new awards under the DO3 PAD.

Although some of the actions in these activities are included in LAC-IEE-17-22, the Mission Environment Officers (MEOs) decided to create a new IEE under the advice of the Regional Environment Advisor (REA) and Bureau Environment Officer (BEO). The new activities entitled “Combatting Extortion and Gang Recidivism by Countering Criminal Impunity” and “Mitigate Corruption and Impunity related to Elections and Political Processes” are further described in section 1.3.

1.3 PROJECT DESCRIPTION

The lack of effective citizen participation and governmental and non-governmental oversight mechanisms contributes to poor allocation and management of public funds and increased opportunities for officials to use their positions for private gain. This hampers the ability of the GOH to effectively implement long-term poverty and violence reduction strategies.

DO3 aims at working with civil society and the government under the hypothesis that if civil society is able to influence government decision-making through enhanced oversight of public programs and evidence-based advocacy, and GOH institutions are able to manage public funds more effectively and responsibly through strengthened budget processes and systems to prevent, detect, and sanction corrupt practices, then national-level public administration will be more transparent and accountable. This in turn will enable the GOH to reduce opportunities for corruption and achieve sustainable development reforms, including reducing extreme poverty

DO3 is aligned with governance, transparency, and accountability goals included in the U.S.

Strategy for Engagement in Central America (CEN Strategy), Alliance for Prosperity (A4P) Plan, GOH Open Government Partnership (OGP) commitments, the Journey to Self-Reliance and the recently updated Embassy Honduras Integrated Country Strategy (ICS) FY 2017-2019. DO3 complements both DO1 and DO2. Furthermore, DO3 promotes country systems and sustainability with its focus on the effective management of public funds and is aligned with the Effective Institutions Platform (EIP) and Sustainable Development Goals (SDGs) 16 and 17.

DO3 aims at achieving four Sub-Intermediate Results (IRs), namely:

➢ Sub-IR 3.1.1: Systems to prevent, detect and sanction corrupt practices strengthened

➢ Sub-IR 3.1.2: Budget process strengthened.

➢ Sub-IR 3.2.1: Effective evidence-based advocacy strengthened

➢ Sub-IR 3.2.2:Oversight of service delivery and public policies/programs improved

The USAID/Honduras Mission plans to attain the DO3 objective through several activities or awards. Each activity contributes to one or more sub-IRs. To facilitate environmental analysis, this document has identified primary action types. The action type is not an individual undertaking. Every action type includes elements which may cause similar environmental effects, and therefore need similar monitoring and mitigation measures. The action types identified for the DO3 include:

Action Type 1:Provide specialized technical assistance to enhance organizational capacity of GOH, Civil Society Organization (CSOs) and other relevant stakeholders to fulfill their functions and deter corruption.

Action Type 2: Facilitate and strengthen multi-stakeholder coalitions to increase their planning and implementation capacity to fulfill their mandate in a transparent and accountable manner.

Specific actions include forums, graduate programs, mentoring support in strategic planning.

Action Type 3:Provide training and other capacity building actions to GOH and non-governmental actors to increase transparency and deter corruption.

Action Type 4: Support studies, analyses and other academic research workshops and meetings aimed at generating information to monitor anti-corruption practices.

Action Type 5: Small-scale (less than 1000 m2) refurbishing and maintenance of existing structures.

Action Type 6: Specific actions for sub-awards are not yet known, but would likely fall under one of the following sub-action types:

Action Type 6.a.: Sub-awards would support training, technical assistance, planning, and studies.

Action Type 6.b.: Sub-awards may be used for small-scale (less than 1000 m2) refurbishing of existing structures.

Action Type 6.c.: Sub-awards may provide basic equipment such as computers, printers etc.

TABLE II: DO3 ACTIVITY DESCRIPTION3

Activity Name

(TEC, LOP)

Description Contribute to Sub-

IR

National Anti-Corruption Council (CNA)

$4.5 million

June 2017- June 2022

The objective of the direct grant to CNA is to strengthen its internal capacity and ability to collaborate with relevant state institutions that can help detect, investigate and prosecute corruption cases.

Sub IR 3.1.1.

Sub IR 3.2.1

Fiscal Transparency (FT) Activity

$9.5 million

Sept 2017- Sept 2021

The FT activity assists the Government of Honduras (GOH) to implement prioritized anti-corruption measures and commitments included in the Open Government Partnership (OGP) Third Action Plan (2016-2019), and recommendations made by MACCIH and Asociacion para una Sociedad más Justa (ASJ) that pertain to the Supreme Audit Institution (TSC). The objective of the FT activity is to strengthen targeted GOH institutions’ capacity to manage public funds more effectively, transparently and responsibly in accordance with international standards and citizen input. Areas of focus include transparency in civil service, monitoring of public investment, public procurement reforms, fiscal transparency and internal and external audits. This may imply provision of training/TA on topics such as change management and systems as well as the purchasing of equipment through sub-awards.

Sub-IR 3.1.1

Sub-IR 3.1.2

Sub-IR 3.2.2

3 USAID/Honduras acknowledges there are some activities which will also receive funding from DO3 and are not covered under this IEE, namely: Transforming Markets Systems (TMS) and potentially: Justice, Human Rights and Security Strengthening Activity (Unidos) and Honduras Local Governance (HLG). For these activities, MEOs hereby confirms the complete environmental analysis (considering all actions and estimated cost) was done under the DO2 IEE for TMS and HLG and DO1 IEE for Unidos.

Civil Society and Media Activity

$9,962,000

April 2018 -April 2022

This activity engages non-traditional civil society actors focused on combating corruption and ensuring public funds are used efficiently and responsibly, and responding to citizen needs.

The activity aims to improve the next generation’s capacity to understand the national budget, how funds are being used, and ways to improve the direction and execution of those funds through increased advocacy skills. The activity provides tools to a range of actors to push the GOH to be more transparent and accountable to citizens and maintain a sustained focus on implementing longer-term development strategies. Actors include, but are not limited to, non-governmental organizations, youth groups, movements, transparency coalitions, private sector and academia.

Sub-IR 3.1.1

Sub-IR 3.2.1

Sub-IR 3.2.2

NEW ACTIVITY

Combatting Extortion and Gang Recidivism by Countering Criminal Impunity (Countering Criminal Impunity)

Propose $20-25 million

Start date: TBD 2021-2026

This activity will provide assessments, expert guidance, mentoring, training, and equipment to the GOH (including the Attorney General’s Office and Judiciary Branch) in order to augment ongoing GOH efforts to improve services provided by justice institutions, especially the recently created specialized unit within the Attorney General’s Office and the Anti-corruption jurisdiction. This Activity will seek to complement and build upon the success of MACCIH and CNA.

Sub IR 3.2.1 Sub IR 3.2.2

Mitigate Corruption and Impunity related to Elections and Political Processes (Mitigate corruption in elections)

$1 million

Start date: TBD

USAID/Honduras will address political will and abuse of state resources that corrode public trust and degrade government legitimacy. Government legitimacy is needed now more than ever to respond to the COVID-19 pandemic. These funds to support the new electoral bodies created in August 2019 will bridge the trust gap and increase the likelihood that the next national elections, scheduled for November 2021, will not be delayed under the pretense of the GOH's COVID-19 response. This work will focus on bridging the trust gap between citizens that is essential for effective governance and for effectively responding to the COVID-19 pandemic and avoiding the political instability that could result.

Sub-IR 3.1.1

Sub-IR 3.2.1

Sub-IR 3.2.2

Will this project/activity involve construction4as defined by ADS 201 and 303? Yes X No

Description of construction: Refurbishing and maintenance of areas smaller than 1000 m2.

2.0 BASELINE ENVIRONMENTAL INFORMATION

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT(ENVIRONMENT,

PHYSICAL, CLIMATE, SOCIAL, THREATENED AND ENDANGERED SPECIES)

The DO3 is being implemented in Honduras' capital city, Tegucigalpa. It supports civil society organization and government institutions in detecting, investigating and prosecuting corruption cases; and improving transparency and accountability. Most of the actions would be implemented in urban settings within the city.

Honduras has seriously been impacted by climate variability and change, and Tegucigalpa is not an exception. It is one of the cities with high vulnerability to natural disasters such as drought, floods, and landslides. Rapid deforestation, weak environmental legislation, illicit activities and corruption threaten not only the forests, but have negative implications for freshwater sources for the city.

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

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

In Tegucigalpa water reservoir levels have been at an historic low. In January 2020 the “Concepción” Reservoir, which provides more than half the city’s water and is key for water distribution throughout the dry season, was at 42 percent of its capacity, contrasted with 59 percent in the previously driest year from the last decade. In light of the situation, the Government of Honduras (GOH) implemented emergency short-term measures to guarantee water to the population until the start of the rainy season expected for mid-May. These efforts are all aimed at preventing social unrest due to water scarcity, similar to water-related protests experienced in Tegucigalpa in September 2019, when a particular community opposed a construction project which was presumably going to affect another of the city’s key water sources.

Physical and Climate Tegucigalpa is located in the interior highlands central region of the country. The city’s hilly topography needs to be taken into consideration when doing refurbishing actions. Also to take into consideration for some of the actions within the DO3, the interior highlands have a distinct dry season from December to May.

Social Honduras’ estimated population is 9.5 million (INE, 2018). Tegucigalpa is the largest city of the country with an estimated population of 1.2 million people. Tegucigalpa’s population growth is faster due to internal migration from Honduras’ rural areas. The main reason for this displacement is due to employment opportunities in the city. Because of this, unemployment is a larger issue in Tegucigalpa and other larger cities and these regions are under constant pressure from the constant influx of new laborers. This is not surprising given that rural populations suffer from a 71.5% poverty rate, of which 16% are extremely poor. For the urban populations, 60% live in poverty and 54% in extreme poverty.

The Mission’s Biodiversity and Tropical forest Assessments have identified the following actions as key to improve governance in natural resources management. These actions are being incorporated into DO3 activities to support biodiversity conservation. They are:

1. Build capacity for effective enforcement and prosecution through provision of financial or technical assistance to improve the capacity of government agencies to enforce wildlife laws and prosecute wildlife criminals.

2. Include actions that strengthen justice sector awareness and investigation capacity for prosecution of illegal activities that threaten biodiversity.

3. Identify opportunities to engage on human rights issues related to water quality, land allocation and compensation or other topics with high public interest.

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER

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

POLICIES, AND REGULATIONS

The DO3 Project will follow Honduran environmental laws and regulations; and USAID’s environmental requirements as per 22 CFR 216 and ADS 204. In addition to USAID Reg. 216 requirements, the project shall obtain all required permits from the appropriate GOH officials The environmental regulatory framework for this Project is guided by the following regulations:

Honduras National Environmental Law (Ley General del Ambiente) applies to all activities of the DO3 Project. The General Environmental Law (Decree 104-93 of May 27th, 1993) created the National Environmental Impact Assessment System (SINEA in Spanish). SINEA coordinates the environmental management and licensing process for all activities (public or private) with a foreseeable potential to affect the environment. The SINEA is coordinated by the Ministry of Natural Resources and Environment's (MiAmbiente) Directorate of Environmental Evaluation and Control (DECA in Spanish). SINEA's structure and procedures for environmental licensing are normed in their updated Regulation (Decree 189-2009, dated December 31, 2009).

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

TABLE III: DO3 Activity Potential Risks and Mitigation Measures

Action Type Activity Potential Environmental Risk

Mitigation Measures

Action Type 1: Provide specialized technical assistance to enhance organizational capacity of GOH, Civil Society Organization (CSOs) and other relevant stakeholders to fulfill their functions and deter corruption.

CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

No negative impact on the environment is expected.

N/A

Categorical Exclusion5 under

22. 216.2(c)(2) (i)

5 Condition for all Categorical Exclusion: USAID will ensure that IP notifies any change in the action or the Activity’s existing environmental conditions which may result in potential negative effect to the environment.

https://www.usaid.gov/our_work/environment/compliance/22cfr216

Action Type 2:

Facilitate and strengthen multi-stakeholder coalitions to improve transparency and deter corruption.

CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

No negative impact on the environment is expected.

N/A

Categorical Exclusion under 22.

216.2(c)(2) (i) and (iii)

Action Type 3: Provide training and other capacity building actions to GOH and non-governmental actors to deter corruption.

CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

216.2(c)(2) (i)

Action Type 4: Support studies, analysis and other academic research workshops and meetings aimed at generating information to monitor anti-corruption practices.

CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

216.2(c)(2) (iii)

Action Type 5: Small-scale (less than 1000 m2) refurbishing and maintenance of existing structures.

CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity.

Small-scale refurbishing activities may generate several environmental and social effects, most common examples include:

i) Emissions and degradation to air quality within the community (noise and air particles);

USAID must ensure IP includes mitigation measures for every foreseen risk. Please refer to USAID’s Construction Sector Environmental Guidelines (SEG)6. For example:

i) Covering materials to avoid loss during transport; fence stockpiles to prevent wind whipping, and ensure all vehicles carrying loose material to or from the site are fully sheeted.

6 https://usaidgems.org/Sectors/construction.htm https://usaidgems.org/Sectors/construction.htm

ii) Effluent discharges or runoff leading to degradation of water quality and impact on the aquatic environment;

iii) Reduction in water and other ecosystem services availability through overuse, leading to conflict between end users.

iv) Poor management of labor and working conditions (for example: lack of security measures, inappropriate handling of materials) resulting in risk to occupational health and safety of workers

v) Habitat removal/compaction resulting in loss and damage to sensitive or valuable ecosystems and use of natural resources.

vi) Land acquisition and resettlement (economic and physical displacement) leading to impacts on community, such as loss of livelihoods, cultural resources, customary uses of land.

vii) Lack of inclusion of indigenous peoples, minorities, and ethnicities, leading to impacts to cultural characteristics; and lack of gender inclusion.

viii) Poor integration into the built environment, exacerbating effects (e.g., poor construction siting, choice of building materials, building orientation, lack of

ii) Identify waste handling facilities close to the project to accept/treat waste (e.g., approved by local government)

iii) Undertake preliminary hydrogeological studies, or at least define the natural drainage characteristics of the area and hydrologically link to the site

iv) The contract should mandate compliance with relevant host country occupational health and safety requirements for construction. Provide personal protective equipment (PPE) such as dust masks to workers on-site. Hire local labor whenever possible.

v) Design into the landscaping plan the protection of existing trees on site serving as a source of shade, windbreak, or providing other benefits

vi) Avoid the need for displacement by developing agreements in local land use and property ownership.

vii) Collaborate with indigenous peoples in all aspects of project design, and consider design alternatives that minimize adverse impacts

viii) Consult with relevant stakeholders to understand local context and key risk areas understanding of the electric system causing systems overload).

Action Type 6.a: Sub-awards would support training, technical assistance, planning, and studies.

FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections

No negative impact on the environment is expected.

N/A

Categorical Exclusion7 under

22. 216.2(c)(2) (i) and (iii)

Action Type 6.b: Sub-awards may be used for small-scale (less than 1000 m2) refurbishing of existing structures.

FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections

Small-scale refurbishing activities may generate several environmental and social effects. Please refer to environmental risks under Action Type 5 (above).

Please refer to illustrative mitigation measures and resources under Action Type 5 (above).

Action Type 6.c: Sub-awards may provide basic equipment such as computers, printers etc.

FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections

Potential environmental impact includes: waste generated from equipment disposition.

USAID must ensure IP includes mitigation measures as part of their disposition plans.

7 USAID will ensure that the IPs verifies that small grants meet this Cat Exclusion. If not, this IEE will be amended, and subsequently the IP will prepare an Environmental Monitoring and Mitigation Plan

(EMMP).

4.0 ENVIRONMENTAL DETERMINATIONS

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS

The following table summarizes the recommended determinations based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22 CFR 216.

Specified conditions, detailed in Section 5, become mandatory obligations of implementation, per ADS 204.

TABLE IV: ENVIRONMENTAL DETERMINATIONS

Activities Categorical

Exclusion Citation (if applicable)

Negativ e Determi nation

Positive Determinatio n8

Deferra l9

Action Type 1: Provide specialized technical assistance to enhance organizational capacity

Activities: CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

22 CFR 216.2 (c)(2)(i) ☐ ☐ ☐

Action Type 2: Facilitate and strengthen multi-stakeholder coalitions to improve transparency and deter corruption.

Activities: CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

22 CFR 216.2 (c)(2) (i) and (iii)

Action Type 3: Provide training and other capacity building actions to GOH and non-governmental actors to deter corruption.

Activities: CNA, FT, Civil Society and Media Activity, Countering

22 CFR 216.2 (c)(2)(i) ☐ ☐ ☐

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

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

Criminal Impunity, Mitigate corruption in elections.

Action Type 4: Support studies, analysis and other academic research workshops and meetings aimed at generating information to monitor anti-corruption practices.

Activities: CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections.

22 CFR 216.2 (c)(2) (iii) ☐ ☐ ☐

Action Type 5: Refurbishing and maintenance of areas smaller than 1000 m2.

Activities: CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity.

Action Type 6.a.: Sub-awards would support training, technical assistance, planning, and studies.

Activities: FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections

22 CFR 216.2 (c)(2)(i) and (iii)

Action Type 6.b.: Sub-awards may be used for small-scale (less than 1000 m2) refurbishing of existing structures.

Activities: FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections

Action Type 6.c: Sub-awards may provide basic equipment such as computers, printers etc.

Activities: FT, Civil Society and Media Activity, Countering Criminal

Impunity, Mitigate corruption in elections

4.2 CLIMATE RISK MANAGEMENT

This section summarizes the methodology used and findings of the CRM Screening, in accordance with ADS 201mal. The project design team, in consultation with the Climate Integration Lead (CIL), considered the potential effects of climate risks/stressors on the sustainability of the project (changing precipitation patterns, rising temperature, floods, droughts, fires, landslides, etc.) in addition to the impact of project activities on the climate (increased greenhouse gas emissions, land use changes, etc.). See Annex 1 for the complete CRM table.

5.0 CONDITIONS AND MITIGATION MEASURES

5.1 CONDITIONS

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

5.1.1 During Pre-Award:

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

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

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

5.1.2 During Post-Award:

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

https://www.usaid.gov/ads/policy/200/201mal

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

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

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

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

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

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

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

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

5.1.2.17 Environmental Compliance Reporting: The A/COR will ensure the IP includes environmental compliance in regular project/activity reports, using indicators as appropriate; develops and submits the Environmental Mitigation and Monitoring Reports (EMMRs); and completes and submits a Record of Compliance (RoC) describing their implementation of EMMP requirements in conjunction with the final EMMR or at the close of sub activities (as applicable).

And where required by Bureaus or Missions, ensure the IP prepares a closeout plan consistent with contract documentation for A/COR review and approval that outlines responsibilities for end-of-project operation, the transition of other operational responsibilities, and final EMMR with lessons learned.

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

5.2 AGENCY CONDITIONS

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

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

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

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

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

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

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

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL

EXAMINATION

The determinations recommended in this document apply only to activities and actions described herein. Other activities that may arise must be documented in either a separate IEE, an IEE amendment if the actions are within the same activity, or other type of environmental compliance document and shall be subject to an environmental analysis within the appropriate documents listed above.

Other than activities determined to have a Positive Threshold Determination, it is confirmed that the activities described herein do not involve actions normally having a significant effect on the environment, including those described in 22 CFR 216.2(d).

In addition, other than activities determined to have a Positive Threshold Determination and/or a pesticide management plan (PERSUAP), it is confirmed that the projects/activities described herein do not involve any actions listed below. Any of the following actions would require additional environmental analyses and environmental determinations:

● Support project preparation, project feasibility studies, or engineering design for activities listed in §216.2(d)(1);

● Affect endangered and threatened species or their critical habitats per §216.5, FAA 118, FAA 119;

● Provide support to extractive industries (e.g. mining and quarrying) per FAA 117;

● Promote timber harvesting per FAA 117 and 118;

● Lead to new construction, reconstruction, rehabilitation, or renovation work per

§216.2(b)(1);

● Support agro-processing or industrial enterprises per §216.1(b)(4);

● Provide support for regulatory permitting per §216.1(b)(2);

● Lead to privatization of industrial facilities or infrastructure with heavily polluted property per §216.1(b)(4);

● Research, testing, or use of genetically engineered organisms per §216.1(b)(1), ADS

● Assist the procurement (including payment in kind, donations, guarantees of credit) or use (including handling, transport, fuel for transport, storage, mixing, loading, application, clean-up of spray equipment, and disposal) of pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials. Pesticides cover all insecticides, fungicides, rodenticides, etc. covered under the Federal Insecticide, Fungicide, and Rodenticide Act per §216.2(e) and §216.3(b).

7.0 REVISIONS

Per 22 CFR 216.3(a)(9), when ongoing programs are revised to incorporate a change in scope or nature, a determination will be made as to whether such change may have an environmental impact not previously assessed. If so, this IEE will be amended to cover the changes. Per ADS 204, it is the responsibility of the USAID A/COR to keep the MEO/REA and BEO informed of any new information or changes in the activity that might require revision of this environmental analysis and environmental determination.

ATTACHMENTS:

Annex 1: Climate Risk Management Summary Table for Projects Annex 2: EMMP Templates: English and Spanish https://drive.google.com/file/d/1cTYt5guvT3-12yhC-YcFrwFEsnh_g0uo/view?usp=sharing https://drive.google.com/file/d/1ORvSa2WaiWi47H6oS4Rivxl3lHPgOmhT/view?usp=sharing https://drive.google.com/file/d/1eDWl1AdaMVsCwZhScG9YAnxHdQmUOurB/view?usp=sharing

ANNEX 1. CLIMATE RISK MANAGEMENT FOR USAID/HONDURAS DO3: SUMMARY TABLE

Defined or Anticipated Project Elements1 Climate

Risks2 Risk Rating3

How Risks are Addressed at Project Leve4l

Further Analysis and Actions for Activity Design/ Implementation5

Opportunities to Strengthen Climate Resilience6

Action Type 1: Provide specialized technical assistance to enhance organizational capacity

Activities: CNA, FT, Civil Society and

Impunity, Mitigate corruption in elections.

No specific climate risk has been identified.

Low

Not Applicable

None is required at this moment

All opportunities to strengthen climate resilience should be analyzed at the Activity Level and included in the Activity EMMP.

Some examples include:

Strengthening anti-corruption efforts will lead to a better use of resources by

Action Type 2: Facilitate and strengthen multi-stakeholder coalitions to improve transparency and deter corruption.

Activities: CNA, FT, Civil Society and

1 Purpose/Sub-purpose, Area of Focus, or Activity/ Mechanism, etc.

2 List key risks related to the project elements identified through either the strategy- or project-level climate risk assessment.

3 Low/Moderate/ High 4 Describe how risks have been addressed at the project level. If a decision has been made to accept the risk, briefly explain why.

5 Describe CRM measures to be integrated into activity design or implementation, including additional analysis, if applicable.

6 Describe opportunities to achieve development objectives by integrating climate resilience or mitigation measures.

Action Type 3: Provide training and other capacity building actions to GOH and non-governmental actors to deter corruption.

Activities: CNA, FT, Civil Society and institutions thus strengthening climate adaptation and mitigation actions efforts done by GOH, private sector and other entities.

Another opportunity exist to build on GOH by training GOH and civil society to help ensure accountability and transparency in environmental resilience and sustainability-related funding.

For refurbishing, opportunities exist to do local planning & Green Infrastructure.

https://portal.hud.gov/ hudportal/documents/

Action Type 4: Support studies, analysis and other academic research workshops and meetings aimed at generating information to monitor anti-corruption practices.

Activities: CNA, FT, Civil Society and

Action Type 5: Refurbishing and maintenance of areas smaller than 1000 m2.

Activities: CNA, FT, Civil Society and Media Activity, Countering Criminal Impunity.

- Physical infrastructure could be impacted by extreme weather events.

Moderate -Include in refurbishing plans materials, training and information on potential extreme weather events.

Include opportunities during design and highlight actions in

EMMP

Action Type 6: Sub-awards to provide inputs, hire specialized personnel and other action aimed at strengthening corruption prevention and investigation actions.

https://portal.hud.gov/hudportal/documents/huddoc?id=greeninfrastructsci.pdf

FT, Civil Society and Media Activity, Countering Criminal Impunity, Mitigate corruption in elections huddoc?id=greeninfra structsci.pdf -use of technology and careful selection of inputs to reduce GHG

EMMP TEMPLATE INSTRUCTIONS

(These are template instructions; please delete this page as you finalize this document).

Background:

This standardized template is part of a broader initiative to harmonize application of 22 CFR 216 across USAID. It also serves as an important step towards moving to an online Environmental Compliance System (ECS) which will be integrated with the Development Information System

(DIS).

This template is used for:

1. This template is to be used to document the Environmental Mitigation and Monitoring

Plan for any project/activity for which the Initial Environmental Examination or Environmental Assessment specified development of an EMMP as a requirement of implementation.

How to use this template:

1. The first page is standard metadata utilized in the ECD and planned DIS system, please do not alter the fields. Enter as much of the information as is known at the time of drafting.

2. On subsequent pages, there are embedded (screen tips) instructions to assist the writer. To see the instructions, hover over the red underlined text. The embedded instructions are intended to streamline the paper template and to simulate the online system. Please ignore reference to “Control+Click to follow link” within the screen tips.

3. All headings and existing text are…