Attachment J.1_IEE-E_E Activity (1).pdf

INITIAL ENVIRONMENTAL

EXAMINATION

PROJECT/ACTIVITY DATA

Project/Activity Name: Employment and Entrepreneurship (E&E) Activity Geographic Location(s) (Country/Region): Rwanda /East Africa Amendment (Yes/No), if Yes indicate # (1, 2...): No Implementation Start/End Date (FY or M/D/Y): FY2022- FY2027

If Amended, specify New End Date: - Solicitation/Contract/Award Number(s): TBD Implementing Partner(s): TBD Bureau Tracking ID: Rwanda E&E IEE https://ecd.usaid.gov/document.php?doc_id=53235 Tracking ID of Related RCE/IEE (if any):

Tracking ID of Other, Related Analyses:

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

USAID/Rwanda

Other Affected Operating Unit(s): - Lead BEO Bureau: Africa Bureau

Funding Account(s) (if available): EG 3.2; EG 5.1; ES 2 Original Funding Amount: $20,000,000

If Amended, specify funding amount: - If Amended, specify new funding total: -

Prepared by: Karis McGill Date Prepared: 4/08/2021

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: ☒Initial 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): N/A Additional Analyses/Reporting Required: N/A Climate Risks Identified (#): Low _1__ Moderate _1___ High _0___ Climate Risks Addressed (#): Low _1__ Moderate _1___ High _0__

Attachment J.1

THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS

PROJECT/ACTIVITY SUMMARY

The USAID/Rwanda Employment and Entrepreneurship (E&E) Activity will address the problem of insufficient employment opportunities for Rwandans which negatively impacts the Rwandan economy and the country's journey to self reliance. E&E will build the capacity of Rwandans, in particular women, youth, and persons with disabilities (PWD), in key technical and soft skills required to participate in a modern workforce (focusing on opportunities surrounding the agricultural economy) and to establish and grow successful enterprises. E&E will use facilitative, demand-driven, private-sector-led approaches to developing economic opportunities at scale.

ENVIRONMENTAL DETERMINATIONS

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

(22 CFR 216).

TABLE 1: ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion Citation (if applicable)

Negative Determinatio n

Positive Determination

Deferral

Curriculum Development and Dissemination

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

Educational Financing §216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

Labor-Market Intermediation §216.2(c)(2)(v) Document and information transfers

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.

Public-Private Dialogues §216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings;

Entrepreneurship Ecosystem Strengthening

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

Grants Under Contract X ☐ ☐ Inclusivity Training §216.2(c)(2)(i)

Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

Inclusive Business Planning §216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

CLIMATE RISK MANAGEMENT

Climate Risk Assessment (Attachment 1) found one potential risk to activity implementation, which will be mitigated by including environmental and climate risk considerations within the grant competition process and will incorporate mitigation measures into individual grant partnership agreements.

BEO SPECIFIED CONDITIONS OF APPROVAL

COVID-19 Condition

In order to reduce COVID-19 transmission during implementation of these activities, USAID managers must:

● Ensure that all activities addressed by this RCE adhere to current, applicable COVID-19 guidelines. Refer to the AFR COVID-19 PIEE (available at https://ecd.usaid.gov/document.php?doc_id=52754) for links to U.S. and international guidance on appropriate measures to reduce COVID-19 transmission. Such measures may include, but are not limited to social distancing, use of personal protective equipment, limiting the size of gathering and travel, and effective disinfection.

● Share with the partner:

○ Applicable COVID-19 guidance from the USAID Mission or U.S. Embassy.

○ Applicable COVID-19 guidance from local authorities.

○ The following Agency-wide “COVID-19 GUIDANCE FOR IMPLEMENTING

PARTNERS” page on the USAID website: https://www.usaid.gov/work-usaid/resources-for-partners/covid-19-guidance-implementing-partners.

Ensure that partners have appropriate training, authorization, and resources to meet the expectations of the applicable guidance while implementing these activities.

Reporting Conditions

The AFR BEO requests that the activity managers (AMs)/ Agreement/Contract Officers Representatives (A/CORs) provide access to the Regional Environmental Advisor (REA) and to the AFR BEO Team to review (not approve) the Environmental Mitigation and Monitoring Plans/Reports (EMMPs/EMMRs) that will be written to implement the findings of this IEE. These should be uploaded into the appropriate sub-folder(s) of this Google Drive folder:

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

This will facilitate access by all parties who need these documents, including the Mozambique Mission (“Mission”) Environmental Officer and the AOR/COR. This will allow the REA and the BEO Team to spot-check and review these documents to confirm that the mitigations seem appropriate and are cognizant of the specific design of the activities.

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/ACTIVITY NAME: Employment and Entrepreneurship

Bureau Tracking ID: https://ecd.usaid.gov/document.php?doc_id=53235

Approval: Cleared electronically 04/21/2021 William Hansen, Acting Mission Director Date

Clearance: Cleared 04/08/2021 Evan Meyer, E&E Activity Planner Date

Clearance: Cleared 04/12/2021 Jean Damascene Nyamwasa, Mission Environmental Officer and Climate Integration Lead

Date

Clearance: Cleared electronically 04/15/2021 David Kinyua, East Africa Regional Environmental Advisor Date

Clearance: Cleared 04/21/2021 Stephanie Altman, Regional Legal Officer Date

Clearance: Cleared 04/12/2021 Amy Beeler, Economic Growth Office Director Date

Clearance: Cleared 05/20/2021 Colin Quinn, AFR Climate Integration Lead Date

Concurrence: 05/20/2021 Brian Hirsch, AFR Bureau Environmental Officer Date

DISTRIBUTION:

INITIAL ENVIRONMENTAL

EXAMINATION

CONTENTS

1.0 PROJECT/ACTIVITY DESCRIPTION 5

1.1 PURPOSE OF the IEE 5

1.2 PROJECT/ACTIVITY OVERVIEW 5

1.3 PROJECT/ACTIVITY DESCRIPTION 5

2.0 BASELINE ENVIRONMENTAL INFORMATION 6

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT,

PHYSICAL, CLIMATE, SOCIAL, Threatened and ENDANGERED species) 6

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER

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

POLICIES, AND REGULATIONS 6

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS

APPROPRIATE) 6

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK 7

4.0 ENVIRONMENTAL DETERMINATIONS 7

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS 7

4.2 CLIMATE RISK MANAGEMENT 7

5.0 CONDITIONS AND MITIGATION MEASURES 8

5.1 CONDITIONS 8

5.2 AGENCY CONDITIONS 9

5.3 MITIGATION MEASURES 10

6.0 187.0

19ATTACHMENTS:

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE OF THE IEE

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID intervention described herein and recommend determinations and, as appropriate, conditions, for these activities. Upon approval, these determinations become affirmed, and specified conditions become mandatory obligations of implementation.

This IEE also documents the results of the Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

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

1.2 PROJECT/ACTIVITY OVERVIEW

The USAID/Rwanda Employment and Entrepreneurship (E&E) Activity will address the problem of insufficient employment opportunities for Rwandans which negatively impacts the Rwandan economy and the country's journey to self reliance. E&E will build the capacity of Rwandans, in particular women, youth, and persons with disabilities (PWD), in key technical and soft skills required to participate in a modern workforce (focusing on opportunities surrounding the agricultural economy) and to establish and grow successful enterprises. E&E will use facilitative, demand-driven, private-sector-led approaches to developing economic opportunities at scale.

1.3 PROJECT/ACTIVITY DESCRIPTION

The overall E&E Activity Objective is to increase inclusive employment and entrepreneurship opportunities for Rwandans. The Activity Objective has three intermediate results, with sub-intermediate results beneath them, as described below. Entrepreneurship, self-employment, and wage-employment are all important avenues to increasing the economic participation and livelihoods of Rwandans, and therefore interventions should be well-balanced to encourage marketable opportunities across all three avenues. For example, training interventions under IR 1 should include skills-building which helps out of work activity participants to harness both entrepreneurship and employment opportunities. Further, interventions under IR 2 will be open to established businesses as well as start-ups, and will include targeted support windows for women youth, and persons with disabilities, who are entrepreneurs but may face additional barriers to accessing the opportunities currently available in Rwanda.

Intermediate Result (IR) 1: Rwandans possess the knowledge and skills required to serve labor and consumer markets domestically, regionally, and globally. Under IR 1 E&E will increase the requisite soft, hard, and technical skills that Rwandan jobseekers and would-be entrepreneurs can bring to market while also increasing their access to information around market opportunities. This IR has three sub-intermediate results:

● 1.1 Quality demand-driven technical, hard, and soft-skill educational opportunities exist at secondary, tertiary, and technical institutes, as well as through employers and other relevant private sector entities.

● 1.2 Educational opportunities increased, with particular emphasis on expanding opportunities to those limited by socioeconomic status, gender or disability.

● 1.3 Job seekers understand the professional opportunities available and the skills needed to attain them.

Intermediate Result 2: The private sector has access to the resources required to grow their revenue and employment. Under IR2, E&E will facilitate access to information and services among businesses that have growth aspirations. These resources can be driven by factors at the macro-level; e.g., public-private dialogues related to regulations and incentives around hiring, firing, human resources, and related business start-up and growth sectors), or at the micro-level, such as entities that provide support to individual businesses that seek growth. E&E will facilitate access to business services that have far-ranging relevance and are demand-driven. Based on stakeholder consultations and learning from relevant Activities, target services are expected to include commercial financing, business planning, legal advising, technical capacity development to market development, linkages finance, and/or to co-investment in upgrading their businesses to achieve economies of scale which will allow them to expand and hire, etc. This IR includes three sub-intermediate results:

● 2.1 The (regulatory) business enabling environment incentivizes firms to grow.

○ Under 2.1 the interventions will focus on general business environment constraints related to taxation, accessing new markets, etc.

● 2.2 The entrepreneurship ecosystem provides comprehensive, appropriate, and accessible services for firms of all sizes.

● 2.3 Employers are able to find skilled workers who meet their labor needs within the local labor market

Intermediate Result 3: Businesses are incentivized to grow inclusively. Under IR 3, E&E will increase the awareness of the social and business case for inclusion (primarily of women, youth, and persons with disabilities) within the business, education, and other institutions supported by or partnered with E&E. As with IR 2, this IR will work at the macro and micro levels; at the macro-level the Activity will advise on the creation and implementation of key anti-discrimination laws and working through institutions to sensitize the population about those laws and their importance. At the micro-level, partners under the Activity will be given individual training and advice for where and how to increase inclusion within their standard operating procedures. This IR will be framed around the following three sub-intermediate results:

● 3.1 Anti-discrimination laws are passed/enforced, and businesses are sensitized and incentivized to comply.

○ Under 3.1, policy work will be specific to inclusion issues such as labor law (including social security set-up, leave policies, etc.) and how to streamline or improve those processes.

● 3.2 Awareness is raised at the societal-level about the importance of inclusion from social, macro-economic, and business-case perspectives.

● 3.3 Businesses incorporate pro-inclusion hiring, administrative, and other policies and procedures.

TABLE 2: DEFINED OR ILLUSTRATIVE ACTIVITY AND SUB-ACTIVITIES

E&E IR 1: Rwandans possess the knowledge and skills required to serve labor and consumer markets domestically, regionally, and globally Curriculum Development and Dissemination: Conduct assessment of currently-approved (buy NESA and RTB) certificate and degree curricula, and provide funding for consultants or other expertise to modernize program offerings and expand them into educational institutions across the country.

Educational Financing: Provide technical assistance to educational institutions and financial institutions to design scholarship and educational lending programs which have loan rate and tenure terms that are aligned with realistic career trajectories of young Rwandans.

Labor-Market Intermediation: Assist job-seekers to access information on employment opportunities and potential employers to access databases of skilled job-seekers. This could include creating and promoting online job search platforms as well as sponsoring in-person matchmaking activities such as career fairs.

E&E IR 2: The private sector has access to the resources required to grow their revenue and employment.

Public-Private Dialogues: Convene relevant businesses, civil society, and national and sub-national government bodies to discuss current regulatory and enabling environment conditions and how they can be improved to achieve activity objectives (ie spur job growth and inclusivity).

Entrepreneurship Ecosystem Strengthening: Technical assistance provision to businesses currently operating within the entrepreneurship ecosystem (such as business development service providers, investors, incubators and accelerators, etc.) to advise on expanding their offerings in order to provide more comprehensive support to businesses across a wider geographic portion of the country.

Grants Under Contract: Provision of catalytic innovation funding to micro, small, medium, and large enterprises in Rwanda with realistic plans for expansion which will result in significant hiring or to invest in upgrades which will allow for the increased inclusion of women, youth, and persons with disabilities within their business models. Grants can also be given to motivated educational institutes, financial institutes, or business development service providers with compelling ideas for spurring job creation.

E&E IR 3: Businesses are incentivized to grow inclusively.

Inclusivity Training: Provide training (across above activity interventions and elements) related to the social, macro-, and micro-economic importance of inclusion of women, youth, persons with disabilities, and other marginalized groups.

Inclusive Business Planning: Provide technical assistance and advisory to individual firms who are interested in finding concrete opportunities to increase social inclusion within their standard operating practices.

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

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

If yes, describe in the space below:

2.0 BASELINE ENVIRONMENTAL INFORMATION

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL,

CLIMATE, SOCIAL, THREATENED AND ENDANGERED SPECIES)

The Rwandan relief is hilly and mountainous with an altitude averaging 1,700 meters. The highest point on Mt Karisimbi is 4,507 meters above sea level. Rwanda has volcanic mountains at the northern fringe and undulating hills in most of the central plateau. However, the eastern part of the country is relatively flat with altitudes well below 1,500 meters. This relief pattern gives Rwanda a mild and cool climate that is predominantly influenced by altitude. Average annual temperatures are about 18.5oC and average rainfall is about 1,250mm per annum.The lowlands of the southwest in Bugarama plain with an altitude of 900m are part of the tectonic depression of the African Rift Valley.

A recent mapping inventory of forests with a surface of 0.5 hectares or higher and with coverage of more than 20% indicated that Rwanda has an estimated 240,746 ha of forests. This is approximately 10% of the surface of the national dry lands [23, 835 sq.km]. Rwanda forests and woodlands fall into four categories: the natural forests of the Congo Nile Ridge comprised with Nyungwe National Park (NNP) Gishwati, and Mukura ; the natural forests of the Volcano National Park (VNP); the natural forests in savannah and gallery-forest of the Akagera National Park (ANP) and remnants of gallery-forests and savannahs of Bugesera, Gisaka and Umutara;

and forest plantations dominated by exotic species (Eucalyptus spp, Pinus spp, Grevillea robusta, etc.) and trees scattered on farmlands (agroforestry) and along anti-erosion ditches.

Rwanda has four types of protected areas which includes national parks (Akagera National Park, Nyungwe National Park and Volcanoes National Park); forest reserves (Gishwati forest, Iwawa Island forest and Mukura forest); forests of cultural importance (Buhanga forest); and wetlands of global importance (Rugezi- Bulera-Ruhondo wetland complex). Besides those forests with a legal status of protected areas, there are other forests of cultural importance (Busaga forest in Muhanga district) and other remnants natural forests which are more or less protected by law. In fact the current law on forests prohibits human activities in natural forests.

Rwanda’s hydrological network includes numerous lakes and rivers and its associated wetlands.

The major lakes include Kivu,Bulera, Ruhondo, Muhazi, Cyohoha, Sake, Kilimbi, Mirayi, Rumira, Kidogo, Mugesera, Nasho, Mpanga, Ihema, Mihindi, Rwampanga and Bisoke. The major rivers include the Akagera, Akanyaru, Base, Kagitumba, Mukungwa, Muvumba, Nyabarongo, and Ruvubu in the Nile Basin and Koko, Rubyiro, Ruhwa, Rusizi, Sebeya in the Congo Basin

A 2008 inventory of wetlands conducted by Rwanda Environment Management Authority (REMA) through Integrated Management of Critical Ecosystems (IMCE) project funded by GEF and World Bank. This inventory showed that Rwanda has 860 marshlands and 101 lakes covering a total surface of 278,536 ha (10.6 percent of the country surface area), and 149,487 ha, respectively. This inventory also found 861 rivers totalling 6,462 km in length. 41 per cent of the inventoried marshlands are covered by natural vegetation, 53 per cent are under cropping, (which represents about 148,344 ha) and about 6 per cent are fallow fields. The biggest marshlands are associated with and clustered around the rivers. Rugezi and Kamiranzovu are high altitude wetlands, most of the others are low altitude.

Despite the important gains that have been made for protecting the environment in recent years, significant threats to environmental well-being remain prominent. The most significant threats to the environment include: population pressure; institutional weaknesses and inefficiencies;

energy pressure; degradation of wetlands and lack of clean water; agricultural inefficiencies and soil erosion; and waste disposal issues.

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL

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

Rwanda constitution addresses certain environmental dimensions, including environmental impact Article 48 states: ‘Any citizen has a right to a safe environment, satisfying and sustainable. Any person has the duty of protecting, maintaining and promoting the environment.

Any act aiming at damaging the environment is punished by the law. The state must protect the environment.’ Later, article 192 forbids any accords authorizing the storing on the Rwandan territory of toxic waste and other substances, which may dangerously damage the environment.

It states: ‘Accords on installation of military barracks on the national territory and those authorizing the storage of toxic waste and other substances which are dangerous for the environment are prohibited.’

Rwanda has made significant progress to establish a stronger foundation for its environmental activities. Some of the important changes that have impacts on the environment include:

● Green Growth and Climate Resilience Strategy (2011)

● Environment and Climate Change Policy (2019)

● Passage of the Organic Law No. 04/2005; Establishment of the Rwanda Environmental

Management Authority (REMA) under Law No. 08/2006;

● Implementation of a government Decentralization Policy and legislation;

● Development and implementation of a land reform process; and

● Provision to the public and private sectors with tools that require the environment to be an integral part of the solutions to critical economic issues with the implementation of the Economic Development and Poverty Reduction Strategy (EDPRS).

The Organic Law on environment is the most significant baseline conservation legislation since 2004. This law serves to: conserve the environment, people and their habitats; set up fundamental principles related to protection of environment; discourage any activities that may degrade the environment; promote the social welfare of the population while considering equal distribution of the existing wealth; consider the durability of the resources with a special emphasis on equal rights to present and future generations; guarantee to all Rwandans sustainable development which does not harm the environment and the social welfare of the population; and establish strategies of protecting and reducing negative effects on the environment and improving/restoring the degraded environment.

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS

APPROPRIATE)

N/A.

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

ACTIVITY 1: EMPLOYMENT AND ENTREPRENEURSHIP

TABLE 3A. POTENTIAL IMPACTS – PROJECT/ACTIVITY 1

E&E Activity Potential environmental and social impacts E&E IR 1: Rwandans possess the knowledge and skills required to serve labor and consumer markets domestically, regionally, and globally Curriculum Development and Dissemination

No potential adverse environmental or related social impacts detected.

Educational Financing No potential adverse environmental or related social impacts detected.

Labor-Market Intermediation No potential adverse environmental or related social impacts detected.

E&E IR 2: The private sector has access to the resources required to grow their revenue and employment.

Public-Private Dialogues No potential adverse environmental or related social impacts detected.

Entrepreneurship Ecosystem Strengthening

No potential adverse environmental or related social impacts detected.

Grants Under Contract Agribusiness enterprises, particularly agricultural processing, can be the source of significant adverse environmental impacts, including BOD (biological oxygen demand) loading of surface waters, water source depletion, odors, and creation of habitat for disease vectors through improper waste disposal.

Storage and sale of agricultural inputs pose hazards associated with improper disposal of containers (including chemical contamination of soil, ground and surface waters), worker and customer hazards, etc.

Without appropriate environmental management practices at the facility level, assistance that increases the scale or number of such enterprises will tend to result in/increase such adverse impacts.

E&E IR 3: Businesses are incentivized to grow inclusively.

Inclusivity Training No potential adverse environmental or related social impacts detected.

Inclusive Business Planning No potential adverse environmental or related social impacts detected.

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 4: ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion Citation (if applicable)

Negative Determinatio n

Positive Determination

Deferral

Curriculum Development and Dissemination

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

Educational Financing

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

Labor-Market Intermediation

§216.2(c)(2)(v) Document and information transfers

Public-Private Dialogues

§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings;

Entrepreneurship Ecosystem Strengthening

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

Grants Under Contract

X

Inclusivity Training §216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

Inclusive Business Planning

§216.2(c)(2)(i) Education, technical assistance, or

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

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

training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

4.2 CLIMATE RISK MANAGEMENT

This section summarizes the methodology used and findings of the CRM Screening, in accordance with ADS 201mal. The project design team, in consultation with the CIL, considered the potential effect of climate risks/stressors on the sustainability of the project (changing precipitation patterns, rising temperature, floods, droughts, fires, landslides, etc.) in addition to the impact of project activities on the climate (increased greenhouse gas emissions, land use changes, etc.). See Annex 1 for the compete 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, REA, BEO) will provide post-award briefings for the IP on environmental compliance responsibilities.

5.1.2.3 Workplans 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 project/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. Activities outside of the scope of the IEE cannot be implemented until the IEE is amended.

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

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

5.1.2.16 Environmental Compliance Mitigation and Monitoring Plan: The 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 fall under a PIEE. The SIEE will provide more thorough analysis of the planned activities, additional geographic context and baseline conditions as well as specific mitigation and monitoring requirements.

5.2.4 Other Supplemental Analyses: The 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.

5.3 MITIGATION MEASURES

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

PROJECT/ACTIVITY 1: E&E ACTIVITY

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

Project/Activity Mitigation Measure(s) Curriculum Development and Dissemination

N/A: None Needed

Educational Financing N/A: None Needed Labor-Market Intermediation N/A: None Needed Public-Private Dialogues N/A: None Needed Entrepreneurship Ecosystem Strengthening

N/A: None Needed

Grants Under Contract -Where assistance to specific enterprises is contemplated, a condition of support is that the enterprise employs (or will employ, as a result of the assistance) adequate environmental management techniques. These techniques must, at a minimum, satisfy obligations under Rwanda laws or policies.

Where no such requirements exist, the enterprise must employ appropriate, common-sense practices to safely dispose of waste, minimize pollution of surface or groundwater, and safely store inputs and commodities.

-Existing processing enterprises/facilities receiving direct USAID support will be reviewed to identify any significant deficiencies in basic environmental management (see the GEMS Food Processing Cleaner Production Factsheet at 28 http://www.usaidgems.org/mse/foodProcessing.htm) or compliance with Rwandan environmental and health requirements, and these deficiencies promptly corrected.

-Any pilots and demonstrations will (1) incorporate and promote sound environmental management practices (see GEMS Food Processing Cleaner Production Factsheet http://www.usaidgems.org/mse/foodProcessing.htm); (2) convey and comply with Rwandan environmental and public health requirements pertaining to these operations.

-In addition to the elements above, training for business development services providers will, where appropriate, incorporate Cleaner Production (CP) approaches, and staff providing such training will have a working knowledge of CP concepts and basic CP skills at least equivalent to the content of the USAID/AFR GEMS training course “Improving Success Rates of MSMEs through Cleaner Production” http://www.usaidgems.org/sme.htm (www.encapafrica.org/sme.htm).

-As applicable, complementary Technical assistance (TA) to agricultural service providers, extensionists, and/or smallholders in sound agricultural practices will be conducted by firms supported under this activity.

- 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. The environmental screening tool that will be deployed is the Africa Bureaus’ Environmental Review Form (ERF), unless otherwise agreed with the AFR BEO Team. The process and findings of the ERF for each sub-award will be documented by the IP and provided to the A/COR. All sub-awards which are designated as low-risk (utilizing the process and guidance outlined in Step 3a of the ERF) will be eligible for A/COR approval. All sub-awards categorized as moderate-risk or unknown-risk (utilizing the process and guidance in Step 3b of the ERF) will be sent by the A/COR to the Mission Environmental Officer (MEO) and Regional Environmental Advisor (REA) for additional clearance.

All sub-awards found to be “high-risk” (utilizing the process and guidance outlined in Step 3a of the ERF) will need to be sent from the A/COR to the Bureau Environmental Officer (BEO) as an additional level of clearance before approval.

Inclusivity Training N/A: None Needed Inclusive Business Planning N/A: None Needed

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION

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

Other than projects/activities determined to have a Positive Threshold Determination, it is confirmed that the projects/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 projects/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 Activity

ANNEX 1. ACTIVITY CLIMATE RISK MANAGEMENT SUMMARY TABLE

Tasks/Defined or Illustrative Interventions

Climate Risks6 Risk Rating7 How Risks are Addressed8 Opportunities to Strengthen Climate Resilience9

Curriculum Development and Dissemination

USAID has not identified any climate risks.

None N/A Curriculum development and upgrading is an opportunity to review the climate information currently being taught in Rwanda and expand upon climate considerations, especially for agricultural training programs.

Educational Financing USAID has not identified any climate risks.

None N/A

Labor-Market Intermediation

USAID has not identified any climate risks.

None N/A

Public-Private Dialogues

USAID has not identified any climate risks.

None N/A Businesses engaged under the grants component will be close, long-term partners of the activity and part of the due diligence process will include environmental compliance checks and environmental risks planning. These businesses will also likely be important players within the larger agricultural sphere in Rwanda.

E&E will work with those businesses to improve their business practices as it relates to environmental and climate considerations. This can have the effect of “crowding in” good climate practices as other businesses emulate the leading firms within the country.

Entrepreneurship Ecosystem Strengthening

USAID has not identified any climate risks.

None N/A

Grants Under Contract

Production: Climate change impacts the agricultural sector in Rwanda. In particular, changing temperature and rain patterns present a risk to agricultural production across the country.

Businesses engaged in the agricultural and food sectors may face unforeseen climate change impacts over the course of E&E activity implementation such as drought or flooding decreasing yields.

Medium E&E partners and grantees will be selected in part based on having well-refined business models, which will include having risk mitigation plans.

Within the agricultural sector this could include sourcing plans which rely on buying from multiple locations so if one district is particularly hit by drought or flood, etc., the business has alternative sources. And/or risk mitigation can include modernized production practices such as employing irrigation or utilizing greenhouses.

6 List key risks related to the defined/illustrative interventions identified in the screening and additional assessment.

7 Low/Moderate/ High 8 Describe how risks have been addressed in activity design and/or additional steps that will be taken in implementation. If you chose to accept the risk, briefly explain why.

9 Describe opportunities to achieve multiple development objectives by integrating climate resilience or mitigation measures

Grants Under Contract

Transportation: Climate change may lead to increased or erratic rain patterns which can flood roads, making transportation from field to processor or to market difficult or impossible while flooding conditions persist. This would impact traders, processors, and wholesalers.

Low E&E will be conducted as part of a suite of USAID/Rwanda Economic Growth programming which includes a Rural Feeder Roads activity which aims to improve the infrastructure for getting goods from areas of production to markets. These improved roads will decrease the likelihood of flooded roads and the length of flooded conditions. Further, environmental risk mitigation plans within specific business partnership agreements can address flood risk for businesses who work in particularly perishable crops which might go bad while waiting 1-3 days for flooding to recede.

Same as above.

Inclusivity Training USAID has not identified any climate risks.

None N/A

Inclusive Business Planning

USAID has not identified any climate risks.

None N/A