Attachment J.16 - OTI Global IEEE.pdf

TRACKING ID: CPS OTI Global IEE_2022 - 2032

USAID/CPS OFFICE OF TRANSITION

INITIATIVES - GLOBAL INITIAL

ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY DATA

Geographic Location(s): Global

Project/Activity Name: CPS Office of Transition Initiatives

Implementation Start/End: 2022-2032

Solicitation/Contract/Award Number: SWIFT IDIQ Task Orders and various other contracts and agreements administered by OTI

Implementing Partner (If Applicable): Multiple

ADMINISTRATIVE DATA

Implementing Operating Unit(s): Bureau for Conflict Prevention and Stabilization

(CPS)

Funding Operating Unit(s) Office of Transition Initiatives (OTI)

Amounts, Including any Amendments ($): $6,300,000,000.00

Funding Accounts: Transition Initiative (TI), ESF, DA, CCF, 1207, and others

Relevant Operating Unit Contact: Lena Kukelhaus

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Lead BEO Bureau: CPS

Analysis Type: OTI Global Initial Environmental Examination (G-IEE)

Environmental Determination(s): Categorical Exclusion, Deferral

Prepared by: Allison Brown, CPS BEO

USAID/CPS OTI GLOBAL INITIAL ENVIRONMENTAL EXAMINATION – SEPTEMBER 2022

Date Prepared: 06/01/2022

Expiration Date: 9/30/2032

Additional Analyses Required: Supplemental Country IEEs (C-IEEs), Environmental Mitigation and Monitoring Plans (EMMPs), Institutional Arrangement Plans (IAPs)

COMPLIANCE DOCUMENTATION TRACKING

For Current Analysis: CPS OTI Global IEE_2022-2032 https://ecd.usaid.gov/document.php?doc_id=54680

IEE Amendment? (Y/N): N

To Other Related Analyses: CPS OTI Global IEE_2017-22 https://ecd.usaid.gov/document.php?doc_id=50522

SUMMARY OF FINDINGS

PURPOSE AND SCOPE OF THE INITIAL ENVIRONMENTAL EXAMINATION (IEE)

The purpose of this document is to summarize administrative clearance and technical analysis for activities to be undertaken by the Office of Transition Initiatives (OTI) to support U.S. foreign policy objectives. The OTI Global Initial Environmental Examination (G-IEE) is a worldwide, preliminary assessment of environmental impacts, climate risks, and policies for OTI activities.

The G-IEE provides the following: a) regulatory threshold determinations; b) analysis of environmental impact and climate risk; and c) conditions for environmental impact and climate risk mitigation, monitoring, and reporting.

The G-IEE serves as a pre-award and start-up phase decision document for the purpose of obligating funds to Implementing Partners (IPs) and fulfills the pre-obligation requirements of Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), USAID Automated Directives System (ADS) chapters 201 and 204.

CONDITIONS

This “Conditions” section applies to OTI's country program awards, typically implemented through the Support Which Implements Fast Transitions (SWIFT) Indefinite Delivery Indefinite Quantity (IDIQ) mechanism; not OTI's operational awards. If you are uncertain if your award falls under this section, please reach out to your COR/AOR.

USAID Contracting Officer’s Representatives (CORs)/Agreement Officer’s Representatives (AORs) must ensure that OTI IPs comply with the following conditions to effectively manage, mitigate, or avoid identified climate risks and environmental impacts:

Pre-Award (No analysis required as part of Request For Task Order Proposal (RFTOP) submissions)1:

1. Familiarity with the G-IEE (and associated annexes) as included with proposal solicitation (e.g., SWIFT IDIQ RFTOPs).

2. Preparation and Inclusion of an Environmental Capabilities Statement (such as in the

SWIFT IDIQ Proposal Submission). The Environmental Capabilities Statement (ECS) must: articulate the IP’s anticipated approach for fulfilling climate risk and environmental management requirements with regards to internal staffing, institutional arrangements, and program budget. Specifically, the ECS must articulate how the IP will be able to effectively respond to all climate risk and environmental management conditions established in the G-IEE and the Country Initial Environmental Examination (C-IEE) throughout OTI program implementation.

Post-Award:

3. Environmental Impact and Climate Risk Verification. During program Start-Up and throughout the life of a program, the OTI IP must review planned activities against the scope of the “Activity Type” classifications in this G-IEE or embedded within their approved C-IEE, and confirm that the planned activities fall within the classifications provided. Activities that are Categorical Exclusions (also referred to as “Cat. Ex.”)2 may proceed without further USAID clearances prior to the C-IEE suite. IPs are responsible for using the OTI Activity Database3 to verify and document that activities undertaken during program Start-Up are within the scopes of the Activity Types (see section 1.3) assigned as Categorical Exclusion in this approved G-IEE. In the event that a proposed activity does not fall within the scope of any of the approved Categorical Exclusion. Activity Types in the G-IEE, implementation may not occur until CPS BEO approval is obtained for the C-IEE, EMMP, and IAP or a One-Off Activity Approval Request (Annex D).

4. Development of a Country-IEE (C-IEE) Suite, including the Environmental Mitigation and Monitoring Plan (EMMP), and Institutional Arrangement Plan (IAP).4 The IP will develop a set of program specific documents (see templates provided) that lay out the following:

a. Country Initial Environmental Examination (C-IEE) (Annex A) - An analysis of the environmental impacts of the identified Activity Types. The C-IEE will include country context, specific Activity Types, the anticipated environmental impacts associated with each Activity Type, and Activity Type specific conditions.

b. Development and Implementation of an Institutional Arrangement Plan (IAP) (Annex B) - The IP’s staffing structure that relates to environmental compliance. The plan will identify those positions or individuals that will be capable and available to provide knowledge and oversight necessary to ensure that environmental impacts and climate risks are effectively minimized.

c. Environmental Mitigation and Monitoring Plan (EMMP) (Annex C) - A plan that identifies mitigation measures to address potential environmental impacts and climate risks. These will be organized by Activity Type as identified in the C-IEE.

5. Integrate Environmental Compliance and Climate Risk Management Language in

1 These Conditions serve to highlight general expectation that implementing partners will have an overarching understanding of the environmental compliance and climate risk management requirements for OTI programs and to clarify the full extent to which environmental compliance and climate risk management requirements are embedded within OTI’s program cycle.

2 Under 22 CFR 216, a Categorical Exclusion is an environmental threshold determination given to actions for which there are no or minimal potential environmental impacts.

3 The OTI Activity Database is described in additional detail in Section 1.2. The environmental impact risk (Categorical Exclusion or Negative Determination with Conditions) and the climate risk rating (Low, Moderate, or High) should also be recorded in the Database for all activities for the life of the program.

4 Word versions of the required templates can be found at a Google drive here:

https://drive.google.com/drive/folders/139I57a_3G9FfSsCN7sl6pjYR_AVp7BPJ.

USAID/CPS OTI GLOBAL INITIAL ENVIRONMENTAL EXAMINATION – SEPTEMBER 2022

https://drive.google.com/drive/folders/139I57a_3G9FfSsCN7sl6pjYR_AVp7BPJ

Sub-Grants and Sub-Awards - All implementation conditions established in this G-IEE, and subsequently in the program’s C-IEE, that apply to an IP’s programming must be passed on to any sub-grantees and sub-awardees, via their solicitations and contracts or agreements.

This includes providing resources and information to sub-grantees and sub-awardees to ensure appropriate hand-off of environmental compliance and climate risk management responsibility, at the end of an activity.

6. Environmental Mitigation and Monitoring Reporting (EMMR) (Annex F) - Following activity implementation and associated environmental and climate risk mitigation and monitoring, the status of environmental compliance and climate risk management must be reported upon on a semi-annual basis through the submission of an EMMR.

7. Adhere to Local Laws and Regulations - In all cases, implementation will adhere to applicable partner country environmental laws, except where the laws are in conflict with USAID regulations or requirements, in which case the latter shall take precedence.

Identification of country and local laws and regulations are a required and an important aspect of the C-IEE.

8. Adhere to Environmentally Sound Design and Management - All activities should adhere to USAID’s standards for environmentally sound design and management, per USAID’s Sector Environmental Guidelines and other reputable best practice resource guides relevant to OTI’s areas of implementation.

ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

An Environmental Threshold Determination (ETD) is a formal USAID decision provided in an initial environmental examination (G-IEE or C-IEE) which determines whether a proposed action is expected to significantly affect the environment. The ETD can be recommended by the IP, but is ultimately decided and finalized by USAID. There are three ETDs, two of which are commonly applied to activities undertaken by OTI programs:

1-Categorical Exclusions (“Cat. Ex.”). A Categorical Exclusion is assigned to activities with low or no environmental impact, 2-Negative Determination with Conditions (also referred to as NDw/C). A Negative Determination with Conditions, is assigned to activities with moderate potential environmental impacts that are mitigable through adherence to certain conditions and mitigation measures., 3-Positive Determinations. A Positive Determination is assigned to activities with high potential environmental impacts. If a Positive Determination is assigned, environmental review of that activity is elevated beyond a C-IEE to a Scoping Study and potentially an Environmental Assessment per 22 CFR 216.6. Due to the nature of OTI’s work Positive Determinations are very rare.5

5 A positive determination does not preclude OTI from undertaking an activity. It does require additional analysis, so reach out to the COR and CPS BEO as early as possible.

TABLE 1. ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

Activity Types Examined by this G-IEE Recommended Environmental Threshold Determination

Recommended Climate Risk Rating6

1. OTI Internal Operational Activities (Non-programmatic Awards)

Categorical Exclusion per §216.2(c)2(i), (iii), (v); and Federal Register Doc E9–21740

Low

2. Capacity building/technical assistance Categorical Exclusion per §216.2(c)2(i), (iii), (v)

Low, Moderate or High, context dependent, as in ADS 201mal, Sec

3. Analyses and studies

4. Social institution building or strengthening

5. Strategic communications and public information/outreach

6. In-kind provisions

7. Repair and rehabilitation of buildings, small-scale new construction

Deferral, to be assessed in

C-IEE

Deferral, to be assessed in C-IEE

8. Small-scale road improvements

9. Small-scale water and sanitation improvements

10. Solid waste management

11. Debris management

12. Commodity procurement

13. Small-scale renewable energy

14. Small-scale agriculture

15. Festivals and events

16. Micro and small enterprises (MSEs) support

6 Categorically Excluded activities are not always low climate risk

Activity Types Examined by this G-IEE Recommended Environmental Threshold Determination

Recommended Climate Risk Rating6

17. Activities not otherwise defined or covered under this G-IEE

TABLE OF CONTENTS

SUMMARY OF FINDINGS 2

PURPOSE AND SCOPE OF THE INITIAL ENVIRONMENTAL EXAMINATION (IEE) 2

CONDITIONS 2

USAID APPROVAL OF GLOBAL INITIAL ENVIRONMENTAL EXAMINATION 7

TABLE OF CONTENTS 8

1 BACKGROUND AND PURPOSE 10

1.1 PURPOSE AND SCOPE OF GLOBAL IEE 10

1.2 OTI PROGRAMS DESCRIPTION 10

1.3 OTI Activity TypeS 11

1.4 LIMITATIONS OF THIS GLOBAL IEE 14

2 GEOGRAPHIC AND IMPLEMENTATION CONTEXT 14

2.1 COUNTRY AND ENVIRONMENTAL INFORMATION 14

3 ENVIRONMENTAL IMPACT AND CLIMATE RISK ANALYSIS FOR OTI Activity TypeS 15

3.1 OTI INTERNAL OPERATIONAL ACTIVITIES 16

3.2 CAPACITY BUILDING/TECHNICAL ASSISTANCE, 3.3 ANALYSES AND STUDIES, 3.4

SOCIAL INSTITUTION BUILDING OR STRENGTHENING, 3.5 STRATEGIC COMMUNICATIONS AND

PUBLIC INFORMATION/OUTREACH 16

3.3 IN-KIND PROVISIONS 17

3.7-3.9 VERTICAL AND HORIZONTAL INFRASTRUCTURE 17

3.10-3.11 SOLID WASTE MANAGEMENT AND DEBRIS MANAGEMENT 18

3.12 COMMODITY PROCUREMENT 18

3.13 RENEWABLE ENERGY 18

3.14 SMALL-SCALE AGRICULTURE 18

3.15 FESTIVALS AND COMMUNITY EVENTS 19

3.16 MICRO AND SMALL ENTERPRISES (MSES) SUPPORT 19

3.17 ACTIVITIES NOT OTHERWISE DEFINED OR COVERED UNDER THIS G-IEE 19

4 ENVIRONMENTAL THRESHOLD DETERMINATIONS (ETDs) AND CLIMATE RISK RATINGS 19

4.1 RECOMMENDED ENVIRONMENTAL THRESHOLD DECISIONS AND CLIMATE RISK

RATINGS 19

4.2 SUMMARY OF IMPLEMENTATION CONDITIONS 22

4.3 PRE-AWARD (NO ANALYSIS REQUIRED AS PART OF RFTOP PROPOSAL SUBMISSIONS)

4.4 POST-AWARD 24

4.5 CLIMATE RISK MANAGEMENT SCREENING 33

4.6 CLIMATE RISK MANAGEMENT SCREENING SUMMARY NARRATIVE 38

ACRONYM LIST 39

LIST OF OTI GLOBAL IEE ANNEXES 40

USAID/CPS OTI GLOBAL INITIAL ENVIRONMENTAL EXAMINATION – SEPTEMBER 2022

http:3.10-3.11

1 BACKGROUND AND PURPOSE

1.1 PURPOSE AND SCOPE OF G-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, recommend determinations, and, as appropriate, conditions for implementation of activities most commonly undertaken by the USAID Bureau for Conflict Prevention and Stabilization (USAID/CPS) Office of Transition Initiatives (OTI). Upon approval, these determinations become affirmed, per 22 CFR 216 and ADS 204, and specified conditions become mandatory obligations of implementation. This analysis also documents the results of the Climate Risk Management process for Activity Types given a Categorical Exclusion in this G-IEE, in accordance with USAID policy (ADS 204, ADS 201 Mandatory Reference 201mal7).

This environmental analysis is a critical element of USAID’s mandatory environmental review and compliance process, meant to achieve environmentally sound activity design and implementation. Potential environmental impacts and climate risks should be addressed through formal environmental mitigation and monitoring plans (EMMPs) as referenced in Condition 4c.

Specifically, this G-IEE establishes overarching environmental compliance and climate risk management requirements and procedures for OTI programming, which include:

1 Global threshold decisions and climate risk ratings for activities expected to have minimal adverse environmental impact.

2 Program level requirements for environmental impact and climate risk analysis, mitigation implementation, and oversight.

3 Environmental impact and climate risk mitigation, monitoring, and reporting conditions to ensure effective management thereof (including institutional arrangements and effective impact/risk mitigation measures) throughout OTI program implementation.

Additionally, this G-IEE establishes overarching environmental compliance and climate risk management requirements and procedures for various OTI managed and primarily DC-based awards that support OTI’s central operations.

1.2 OTI PROGRAMS DESCRIPTION

OTI programs work with local partners to target key political issues such as conflict, democratic backsliding, violent extremism, and stabilization, while delivering high quality, vanguard programming in fast-paced contexts. OTI works closely with USAID regional bureaus, missions, and other counterparts to continually identify and respond to strategic needs in the immediate term that help to stabilize a situation, buy time for longer-term political and economic reform, complement other assistance efforts, and lay a foundation for development efforts to succeed.

One of OTI’s primary in-house contracting mechanisms, SWIFT, allows OTI to use contractors competitively selected through an indefinite delivery indefinite quantity (IDIQ) contract to quickly establish offices and begin approving activities and disbursing grants. OTI generally uses small, quickly implemented activities, typically valued at $70,000 that last approximately three to four months, although activities vary in size and time across programs. A typical program implements 100-200 activities each year, and most activities are implemented through in-kind

7 https://www.usaid.gov/sites/default/files/documents/1868/201mal_042817.pdf https://www.usaid.gov/sites/default/files/documents/1868/201mal_042817.pdf grants to local organizations. OTI maintains an Activity Database to track program activities, as well as the purpose(s), amounts, recipients, and status of each activity. This database serves as an important management, oversight, and learning tool for each OTI program.

By using primarily small activities, OTI can pilot new initiatives, learn about the local context with small investments, and refocus program activities if approaches are not effective or new opportunities arise. While OTI may occasionally conduct large activities, more frequently, multiple small activities may be interconnected and “clustered” to achieve a larger objective.

This approach allows both increased flexibility and an opportunity for lessons learned from each phase to be built into each subsequent phase.

In implementation and programming, OTI is guided by a number of strategic principles that have proven especially important for working in transition environments.

● Fast. OTI programs must respond quickly in transitions, much like the emergency response teams of USAID’s Bureau for Humanitarian Assistance. OTI can start up programs in new countries within days or weeks of a decision to intervene and begin activities with small, local groups within days or weeks of award.

● Flexible. Rather than identifying activities in advance during program design, OTI creates mechanisms that can flexibly respond to unanticipated contingencies and emerging opportunities in a transition context. To achieve this flexibility, OTI accords its field staff a high degree of authority over program decisions, and OTI primarily funds small, short-term activities (typically through sub-awards under a prime IP award) instead of developing longer-term work plans with pre-identified activities. An OTI program must have the capability to implement a variety of activities that cut across several technical sectors in order to respond effectively.

● Responsive. OTI activities are designed to respond in a timely manner to events that affect prospects for transition or stabilization programming. OTI may design activities that respond to an ongoing process (e.g., upcoming elections, implementation of a peace agreement), to a specific event (e.g., a flare-up of violence in a neighborhood, a natural disaster), or to some other opportunity that can advance the program’s goals.

Using an iterative process of rolling assessment, OTI uses its activities and its knowledge of local organizations, systems, and processes to adapt activities to the affecting events in a manner that best supports program objectives.

1.3 OTI ACTIVITY TYPES

To facilitate the environmental impact and climate risk analysis for this G-IEE, OTI programming has been organized into the below listed “Activity Types.” An Activity Type is not an individual activity but, instead, it represents a range of types of similar actions that will require similar mitigation measures and monitoring in the EMMP which are tailored to the OTI approach.

As a note: “small-scale” is a concept rather than a specific size. The intent of denoting an action as “small-scale” is to identify it as one that will have minimal environmental impact once mitigation measures have been applied.

The common Activity Types considered in this G-IEE are:

1. OTI Internal Operational Activities8

- Support OTI’s central operations, such as but not limited to, recruitment and workforce support; mapping and data visualization; graphic design;

communications, outreach, and social media support; administrative, operational, and technical support; finance and budget support; acquisition and assistance design and management support; support for capacity building activities (training); ancillary information technology (IT) support for software (not equipment); facilitation; program management and advisory support; staff coaching services; technical IT services support, and monitoring, evaluation, and learning (MEL) services; support for assessments, analyses, reports and/or evaluations; technical assistance

- These activities may be program-funded, but are consistent with the description for Categorical Exclusions for Domestic Internal Operational Activities, as described in the directive in Federal Register Doc E9–21740.9

2. Capacity building/technical assistance

- Providing short-term technical assistance, such as in financial management

3. Analyses and studies

4. Social institution building or strengthening

- Supporting dialogue, creating public forums or similar activities working with communities, groups or individuals

- Conducting analyses and/or studies

- Small10 public gatherings/meetings

5. Strategic communications and public information/outreach

- Surveying/polling a population

- Conducting trainings for strategic planning, information dissemination, media programming and transmission

- Providing communications support to any level of government and to

Nongovernmental Organizations (NGOs)

6. In-kind Provisions11

- Desks, backpacks, pencils, shovels, etc.

7. Repair and rehabilitation of buildings; small-scale new construction

- For example, government and community facilities, schools, small-scale health care facilities, marketplaces, urban parks

8. Small-scale road improvements

- Rehabilitating rural roads

- Rehabilitating urban roads

9. Small-scale water and sanitation improvements (WASH)

- Construction, rehabilitation, or overall improving of drinking water points/sources, water pumps (not for irrigation), latrines, showers/bathing blocks, and wastewater treatment/removal

- Small-scale water treatment systems

10. Solid waste management

- Disposing/storage of general wastes, e.g. organics and recyclables

8 This Activity Type is only for non-Country Program awards.

9 Federal Register Doc E9–21740:

https://www.usaid.gov/sites/default/files/documents/1865/2009_Federal_Register_Cat_Ex_USAID_Domestic_OE-Funded_Activitiee s.pdfmu 10 Small gatherings are any that bring together fewer than 75 people simultaneously.

11 These are commodities that can be disposed of in a municipal waste disposal area without significant potential complications or hazards.

USAID/CPS OTI GLOBAL INITIAL ENVIRONMENTAL EXAMINATION – SEPTEMBER 2022

https://www.usaid.gov/sites/default/files/documents/1865/2009_Federal_Register_Cat_Ex_USAID_Domestic_OE-Funded_Activitiee

- Disposing/storage of medical wastes, e.g. syringes, blood, body fluid, cadavers

- Disposing/storage of industrial waste, e.g. chemicals, toxins, manufacturing/processing byproducts

- Disposing/storage of general hazardous wastes, e.g. household detergents, fuels, electronic waste (“e-waste”)

- Supporting businesses involved in recycling, waste collection and sorting

11. Debris management

- Disposing/removal of standard construction debris, e.g. collapsed buildings of concrete, metal, or wood, used construction materials

- Disposing/removal of hazardous/sensitive materials in debris, e.g. human remains, spent ordnance, live ordnance, spilt chemicals, fuels, or toxins

12. Commodity procurement12

- Computers, phones, IT equipment, emergency power supplies and transformers, moving and transportation equipment

13. Small-scale renewable energy13

- Design and installation of solar panels

14. Small-scale agriculture activities

- Procuring agricultural starter kits, agricultural equipment, and tools

- Veterinary supplies, animal husbandry (e.g. raising livestock/poultry), bee-keeping, dairy production.

- Technical assistance to farmers, training on good agricultural practices or climate smart practices

- Community gardens, tree/flower planting

- Fish ponds and commercial fishing in rural areas

15. Festivals and community events

- Opening ceremonies, sports tournaments, cultural festivals, etc.

- Gatherings of more than 75 people

16. Micro and small enterprises (MSEs) support

- Supporting businesses involved in brick-making, carpentry in urban areas

- Other entrepreneurial support

17. Activities not otherwise defined or covered under this G-IEE

Activities not otherwise defined or covered under this G-IEE can be described and added to the C-IEE for CPS BEO consideration. All Activity Types must be covered by this G-IEE (for Categorical Exclusion only) or approved by an C-IEE and EMMP (for Negative Determinations with Conditions) before they may be implemented. Any activity that is not approved by the G-IEE and/or C-IEE can be considered by submitting a One-Off activity request to the COR/AOR and CPS BEO.

1.4 LIMITATIONS OF THIS GLOBAL IEE

This G-IEE does not provide an Environmental Threshold Decision or Climate Risk Rating for Classes of Actions Normally Having a Significant Effect on the Environment (specified in 22 CFR 216.2 (d)). These activities typically trigger a Positive Determination and therefore require a Scoping Study with possible follow on Environmental Assessment (EA);14 such

12 These are commodities that cannot be thrown away in a municipal waste disposal area without potential complications or hazard.They require special waste management considerations (e.g. hazardous, medical, electronic, toxic, chemical, etc.).

13 Activities not identified here that may fall under the small scale renewable energy Activity Type should be highlighted for and approved by the CPS BEO 14 The specific content of an EA is outlined under §216.6 Environmental assessments and should be reviewed carefully by both the COR/AOR or Activity Manager and the EA Preparer/Contractor. Review ADS 204 at http://www.usaid.gov/ads/policy/200/204.

USAID/CPS OTI GLOBAL INITIAL ENVIRONMENTAL EXAMINATION – SEPTEMBER 2022

http://www.usaid.gov/ads/policy/200/204 activities are often large-scale (e.g., large-scale new road construction, resettlement projects, major water and sanitation projects) or pose particularly complex environmental management considerations (e.g., flood barriers). These activities are rare (if ever) under OTI programs due to the nature and speed of OTI programming.

This G-IEE also does not cover pesticides, including their procurement, transport, storage, disposal, or technical assistance or training related to pesticides use. Should pesticide procurement or use activities be anticipated, the intent must be articulated within the C-IEE.

Additional analytical review and clearance will be required by the CPS BEO, per 22 CFR 216.3(b), USAID’s Pesticide Procedures.

Additionally, this G-IEE does not cover activities in environmentally sensitive areas (e.g., wetlands or protected areas that perform a variety of important environmental functions, such as the provision of wildlife habitat, stormwater drainage, flood water storage, and pollutant entrapment). If activities are anticipated in these areas, they should be flagged for the COR/AOR and CPS BEO and discussed in the C-IEE. Additional analytical review and clearance may be required by the CPS BEO prior to the implementation of these kinds of activities.

2 GEOGRAPHIC AND IMPLEMENTATION CONTEXT

2.1 COUNTRY AND ENVIRONMENTAL INFORMATION

Locations of OTI interventions are not identified in the G-IEE and environmental situations will vary, so detailed country-specific demographic, economic, and environmental information must be completed as part of the C-IEE. This information should include the implementation context (e.g. environmental, social, geopolitical, economic context) that may have a bearing on potential environmental impacts which require mitigation during rehabilitation, operation, demolition or decommissioning of the proposed intervention. Detailed information about the location (e.g., latitude/longitude, Google Map/Earth images, geospatial data) and timing (duration, months of implementation, etc.) should be provided to the extent possible at the time of C-IEE preparation.

Activities implemented by OTI may take place in countries or regions with a USAID Mission, countries covered by USAID Regional Missions, and/or non-presence countries. In addition to complying with 22 CFR 216 and ADS 201 and 204, all OTI program sub-grantees and sub-awardees and their activities must comply with partner country environmental statutes. It is anticipated that programs could be carried out in multiple urban and rural ecosystems or in areas that are beset by poverty and/or are recovering from damage and destruction caused by conflict. Because the specific characteristics and locations of these activities are not defined, the potential adverse environmental impacts (and therefore, environmental threshold determinations) cannot be determined until additional information about program design and location becomes available.

Where specific details about the geographic areas and exact scope of implementation or activities remain unknown at time of preparation of the C-IEE, the IP must complete Section 2.0 of the C-IEE as thoroughly as possible given the information known and clearly articulate any applicable limitations. When such limitations exist, Activity Type details must then be included

Scoping Studies and Environmental Assessments require BEO approval. The CPS BEO should be brought in to Scoping Studies and Environmental Assessments at early stages for consultation as part of the EMMP, clarifying any lingering uncertainties about geographic regions, scale, and scope of planned activities.

3 ENVIRONMENTAL IMPACT AND CLIMATE RISK ANALYSIS FOR

OTI ACTIVITY TYPES

This section of the G-IEE achieves two purposes: First, it defines potential environmental impacts of the proposed program, whether direct, indirect, beneficial, adverse, short-term, long-term, or cumulative. This includes evaluation of the potential adverse impacts that proposed activities may have on the environment, including socioeconomic, gender, and cultural effects. Second, this section identifies climate risks that are anticipated to possibly threaten proposed Activity Types.

Analysis of environmental impacts and climate risks is undertaken for each of the Activity Types introduced in Section 1.3.

● 3.1 OTI INTERNAL OPERATIONAL ACTIVITIES

● 3.2 CAPACITY BUILDING/TECHNICAL ASSISTANCE,

● 3.3 ANALYSES AND STUDIES,

● 3.4 SOCIAL INSTITUTION BUILDING OR STRENGTHENING,

● 3.5 STRATEGIC COMMUNICATIONS AND PUBLIC INFORMATION/OUTREACH

● 3.6 IN-KIND PROVISIONS

● 3.7 REPAIR AND REHABILITATION OF BUILDINGS, SMALL-SCALE NEW CONSTRUCTION

● 3.8 SMALL-SCALE ROAD IMPROVEMENTS

● 3.9 SMALL-SCALE WATER AND SANITATION IMPROVEMENTS (WASH)

● 3.10 SOLID WASTE MANAGEMENT

● 3.11 DEBRIS MANAGEMENT

● 3.12 COMMODITY PROCUREMENT

● 3.13 SMALL-SCALE RENEWABLE ENERGY

● 3.14 SMALL-SCALE AGRICULTURE ACTIVITIES

● 3.15 FESTIVALS AND EVENTS

● 3.16 MICRO AND SMALL ENTERPRISES (MSES) SUPPORT

● 3.17 ACTIVITIES NOT OTHERWISE DEFINED OR COVERED UNDER THIS G-IEE

3.1 OTI INTERNAL OPERATIONAL ACTIVITIES

No significant environmental impacts under the USAID Environmental Compliance Procedures are expected to result from support for OTI’s central operations. These activities include, but are not limited to: recruitment and workforce support; training and organizational development and learning; mapping and data visualization; graphic design; communications, outreach, and social media support; administrative, operational, and technical support; finance and budget support;

acquisition and assistance design and management support; support for capacity building activities (training); ancillary IT support for software (not equipment); facilitation; program management and advisory support; staff coaching services; technical IT services support, MEL services; support for assessments, analyses, reports and/or evaluations; and technical assistance.

These activities may be program-funded, but are consistent with the description for Categorical Exclusions for Domestic Internal Operational Activities, as described in the directive in Federal Register Doc E9–21740.15

CLIMATE RISKS

A low climate risk rating is expected for the internal operation Activity Type.

3.2 CAPACITY BUILDING/TECHNICAL ASSISTANCE, 3.3 ANALYSES AND STUDIES, 3.4 SOCIAL

INSTITUTION BUILDING OR STRENGTHENING, 3.5 STRATEGIC COMMUNICATIONS AND

PUBLIC INFORMATION/OUTREACH

ENVIRONMENTAL IMPACTS

No significant environmental impacts under the USAID Environmental Compliance Procedures are expected to result from capacity-building/technical assistance, social institution support/strengthening, strategic communications and public information/outreach, despite the generation of some amount of solid wastes. In conducting meetings, workshops, and related gatherings, OTI partners should reference and apply the recommendations of the Annex F Green Meeting Checklist.

CLIMATE RISKS

Climate change poses risks to programming in a way that can undermine the impact or success of implementation. As activities are designed, considering the context of the implementation (location, infrastructure, transportation, and communication requirements, etc.) is the best way to identify climate risks. Although it could be assumed that climate risks for strategic communications, public information and outreach, social institution support, and capacity building activities are expected to be minimal, event locations (e.g., locations for workshops and training activities), communication necessities (e.g. radio towers, roads, supply chains) may be exposed to climate risks, including extreme weather events. Weather events such as flooding and storms could affect the structural integrity of buildings and radio towers as well as the ability of participants to reach the location. Insufficient nutrition, increased temperatures, as well as the increasing frequency and severity of heat waves, could affect the health and comfort of individuals participating in capacity building activities, or even their ability to participate.

Regardless of the climate risk rating of the categorically excluded activities, (e.g. low, moderate, or high), the risks will be accounted for in the activity design process and addressed to the extent possible. If addressing the climate risk rating is not possible, the climate risk nature of the activity will be accepted and implementation may proceed.

3.3 IN-KIND PROVISIONS

ENVIRONMENTAL IMPACTS

No significant environmental impacts under the USAID Environmental Compliance Procedures are expected to result from in-kind provision of commodities such as desks, backpacks, pencils, shovels, and other similar items, despite the generation of some amount of solid wastes. These are commodities that can be disposed of in a municipal waste disposal without significant potential complications or hazards.

15 Federal Register Doc E9–21740:

https://www.usaid.gov/sites/default/files/documents/1865/2009_Federal_Register_Cat_Ex_USAID_Domestic_OE-Funded_Activitiee s.pdfmu

USAID/CPS OTI GLOBAL INITIAL ENVIRONMENTAL EXAMINATION – SEPTEMBER 2022

https://www.usaid.gov/sites/default/files/documents/1865/2009_Federal_Register_Cat_Ex_USAID_Domestic_OE-Funded_Activitiee http:E9�21740.15

CLIMATE RISKS

Climate change poses risks to programming in a way that can undermine the impact or success of implementation. As activities are designed, considering the context of the implementation (location, infrastructure, transportation and communication requirements, etc.) is the best way to identify climate risks. Although it could be assumed that climate risks for in-kind provision activities are expected to be minimal, supply chains, distribution of commodities, and the disposal sites of these items may be exposed to climate risks, including extreme weather events.

Regardless of the climate risk rating of this categorically excluded Activity Type, (e.g. low, moderate, or high), the risks will be accounted for in the activity design process and addressed to the extent possible. If addressing the climate risk rating is not possible, the climate risk nature of the activity will be accepted and implementation may proceed.

3.7-3.9 VERTICAL AND HORIZONTAL INFRASTRUCTURE

Including 3.7 Repair and Rehabilitation of Buildings and Small-Scale New Construction, 3.8 Small-Scale Road Improvements, 3.9 Water and Sanitation Improvements.

ENVIRONMENTAL IMPACTS AND CLIMATE RISKS

These activities are likely to have environmental impacts and climate risks, depending on the location and environment in which they are implemented. The G-IEE does not have enough detailed information to make a threshold determination or climate risk rating for these activities.

C-IEEs must provide sufficient activity and background information to receive a threshold determination if this Activity Type is expected to be undertaken by the program. Climate risk ratings will subsequently be documented at the activity level in the Activity Database.

3.10-3.11 SOLID WASTE MANAGEMENT AND DEBRIS MANAGEMENT

ENVIRONMENTAL IMPACTS AND CLIMATE RISKS

These activities may have environmental impacts and climate risks depending on the location and environment in which they are implemented and the type of wastes to be managed. The G-IEE does not have enough detailed information to make a threshold determination or climate risk rating for such activities. C-IEEs must provide sufficient activity and background information to receive a threshold determination if this Activity Type is expected to be undertaken by the program. Climate risk ratings will subsequently be documented at the activity level in the Activity Database.

3.12 COMMODITY PROCUREMENT16

ENVIRONMENTAL IMPACTS AND CLIMATE RISKS

Commodity procurements may have environmental impacts and climate risks depending on the location as well as physical and socio-economic environment in which they are conducted. The G-IEE does not have enough detailed information to make a threshold determination or climate risk rating for these activities. C-IEEs must provide sufficient activity and background information to receive a threshold determination if this Activity Type is expected to be

16 Commodity procurement differs from In-kind provisions in that commodity procurement activities deal with items that have more complicated or hazardous waste management processes. This may include items such as computers, phones, or other IT; batteries or cars; or other items that will require careful and considered waste management.

USAID/CPS OTI GLOBAL INITIAL ENVIRONMENTAL EXAMINATION – SEPTEMBER 2022

http:3.10-3.11 undertaken by the program. Climate risk ratings will subsequently be documented at the activity level in the Activity Database.

3.13 RENEWABLE ENERGY

ENVIRONMENTAL IMPACTS AND CLIMATE RISKS

Renewable energy design, installation, operation and maintenance may have environmental impacts and climate risks depending on the location as well as physical and socio-economic environment in which they are conducted. The G-IEE does not have enough detailed information to make a threshold determination or climate risk rating for these activities. C-IEEs must provide sufficient activity and background information to receive a threshold determination if this Activity Type is expected to be undertaken by the program. Climate risk ratings will subsequently be documented at the activity level in the Activity Database.

3.14 SMALL-SCALE AGRICULTURE

ENVIRONMENTAL IMPACTS AND CLIMATE RISKS

Small-scale agriculture activities may have environmental impacts and climate risks depending on the location as well as physical and socio-economic environment in which they are conducted. The G-IEE does not have enough detailed information to make a threshold determination or climate risk rating for these activities. C-IEEs must provide sufficient activity and background information to receive a threshold determination if this Activity Type is expected to be undertaken by the program. Climate risk ratings will subsequently be documented at the activity level in the Activity Database.

3.15 FESTIVALS AND COMMUNITY EVENTS

ENVIRONMENTAL IMPACTS AND CLIMATE RISKS

Support for festivals and community events may have environmental impacts and climate risks depending on the location and environment in which they are implemented. The G-IEE does not have enough detailed information to make a threshold determination or climate risk rating for such activities. C-IEEs must provide sufficient activity and background information to receive a threshold determination if this Activity Type is expected to be undertaken by the program. Climate risk ratings will subsequently be documented at the activity level in the Activity Database.

3.16 MICRO AND SMALL ENTERPRISES (MSES) SUPPORT

ENVIRONMENTAL IMPACTS AND CLIMATE RISKS

Support to MSEs may have environmental impacts and climate risks depending on the location and environment in which they are implemented, and the types of businesses supported. The G-IEE does not have enough detailed information to make a threshold determination or climate risk rating for such activities. C-IEEs must provide sufficient activity and background information to receive a threshold determination if this Activity Type is expected to be undertaken by the program. Climate risk ratings will subsequently be documented at the activity level in the Activity Database.

3.17 ACTIVITIES NOT OTHERWISE DEFINED OR COVERED UNDER THIS G-IEE

ENVIRONMENTAL IMPACTS AND CLIMATE RISKS

Support for activities not otherwise defined or covered by this G-IEE may be proposed at the OTI program level, and will have environmental impacts and climate risks depending on the nature of the activities, location, and environment in which they are implemented. The G-IEE does not have enough detailed information to make a threshold determination or climate risk rating for such activities. C-IEEs must provide sufficient activity and background information to receive a threshold determination if this Activity Type is expected to be undertaken by the program. Climate risk ratings will subsequently be documented at the activity level in the Activity Database. If programs anticipate implementing a limited set of activities of a certain type, they may also seek One-Off Activity Approval, using the template provided (Annex D of the G-IEE).

4 ENVIRONMENTAL THRESHOLD DETERMINATIONS (ETDS) AND

CLIMATE RISK RATINGS

Section 4.1 recommends a Categorical Exclusion or Deferral for each proposed Activity Type.

For each recommendation, the supporting citation from 22 CFR 216 is listed.

Section 4.2 then describes the conditions for implementation of this G-IEE as a means to avoid, minimize, eliminate, or compensate for environmental impacts.

4.12 RECOMMENDED ENVIRONMENTAL THRESHOLD DECISIONS AND CLIMATE RISK RATINGS

Table 2 below summarizes which OTI program Activity Types are not likely to have adverse effects on the environment (qualifying for Categorical Exclusion), as well as those activities for which insufficient information is available to establish the appropriate Environmental Threshold Determination (ETD) at the G-IEE level (qualifying for Deferral). Those actions qualifying for a deferral cannot be implemented until they are assigned a threshold determination by the CPS BEO in the C-IEE or a One-Off Activity Approval (Annex D). No actions with significant adverse environmental impacts are covered by this G-IEE.

ENVIRONMENTAL THRESHOLD DECISIONS

Categorical Exclusion: A Categorical Exclusion is recommended for Activity Types 1 through 6

- OTI Internal Operational Activities, Capacity building/technical assistance, Social institution building or strengthening/analyses or studies, and Strategic communications and public information/outreach efforts implemented under OTI programs where no environmental impacts are expected as a result of implementation. These activities meet the criteria of 22 CFR 216.2(c)(1) and the classes of action pursuant to 22 CFR 216.2(c)(2).

Deferral: A Deferral is recommended for activities of unknown or unquantifiable risk at the G-IEE stage (Activity Types 7 through 17) and that may be addressed in a C-IEE and corresponding EMMP. Deferrals apply when Activity Types are not yet sufficiently well-defined to allow an assessment of their probable environmental impact. As additional details for the Activity Type become available, USAID may determine that a recommendation for either a Negative Determination with Conditions or a Positive Determination (which would, in turn, trigger a Scoping Study and possible EA per 22 CFR Reg. 216) is appropriate. The environmental threshold determination for these activities shall then be issued under the C-IEE, when more activity-specific information is available. Implementation of deferred Activity Types may not begin until a threshold decision has been made for that activity, and the Activity Types' impacts are assessed and mitigated. This can be done through a One-Off Activity Approval or through clearance of the C-IEE suite, either through the initial C-IEE suite or subsequent amendments.

The environmental impact assessment process, which focuses explicitly on the environmental impact of a proposed action on the environment, runs in parallel to the process of screening for and addressing climate risks for OTI Activity Types. Limiting risks posed by climate change is inextricably linked with understanding and mitigating a program’s or activity’s environmental impact. Landscapes that have become increasingly degraded due to years of poor land management have exacerbated climate risks, for instance. USAID and IPs should strive to help communities better manage their land, air, and water. To limit climate-related risks, and to identify opportunities for improved development outcomes, USAID conducts climate risk management (CRM) screening for strategies, projects, and activities. ADS Mandatory Reference 201mal describes the CRM screening process and requirements, including rating activities as Low, Moderate, or High Climate Risk.

CLIMATE RISK RATINGS17

Table 2 also provides the recommended climate risk rating for each OTI program Activity Type based on the anticipated likelihood and severity of climate risks on an activity’s implementation and outcomes.

A Low Climate Risk rating is recommended for Activity Type 1 - OTI Internal Operational Activities because the climate risk is not expected to materially affect the implementation or outcomes of the activity.

A Low, Moderate, or High Climate Risk rating can be possible recommendations for Activity Types 2 through 6 - Capacity building/technical assistance, Social institution building or strengthening, analyses or studies, and Strategic communications and public information/outreach Activity Types implemented under the OTI program, because climate risks are not expected to materially affect the implementation or outcomes of the activity or will be accepted and integrated as part of the activity design.

A Deferred Climate Risk rating is recommended for Activity Types 7 through 17, encompassing activities of unknown or unquantifiable risk at the G-IEE stage, but that may be addressed in a C-IEE and corresponding EMMPs. Climate risk management screening is necessary to assess, plan for, and document the risks affecting each Activity Type. As additional details for the Activity Types become available, there will be sufficient information to conduct a CRM screening. The IP must conduct a CRM screening for all Activity Types receiving a Deferred Climate Risk Rating. The climate risk rating shall then be issued under the C-IEE, when more activity-specific information is available. Implementation for deferred Activity Types cannot begin until a climate risk screening has been conducted for the relevant Activity Type at the C-IEE level, either through the initial C-IEE or a subsequent amendment, and the activity-specific climate risk rating has been documented in the OTI Activity Database.

17 For those programs working in countries/regions with an approved CDCS/RDCS, the CRM tables can be used to inform climate risks and ratings for OTI program activities. Climate risk ratings for each OTI program activity will be documented in the Activity Database.

TABLE 2. ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

Activity Types Examined by this G-IEE Recommended Environmental Threshold Determination

Recommended Climate Risk Rating18

1. OTI Internal Operational Activities (Non-SWIFT OTI Awards)

Categorical Exclusion per §216.2(c)2(i), (iii), (v) (as defined by footnote 7) and Federal Register Doc E9–21740

Low

Low, Moderate or High, context dependent, as in ADS 201mal, Sec 3

2. Capacity building/technical assistance

Categorical Exclusion per §216.2(c)2(i), (iii), (v)

3. Analyses and studies

4. Social institution building or strengthening

5. Strategic communications and public information/outreach

6. In-kind provisions

7. Repair and rehabilitation of buildings, small-scale new construction

Deferral, to be assessed in

C-IEE

Deferral, to be assessed in C-IEE

8. Small-scale road improvements

9. Small-scale water and sanitation improvements

10. Solid waste management

11. Debris management

12. Commodity procurement

13. Small-scale renewable energy

14. Small-scale agriculture

15. Festivals and events

16. Micro and small enterprises (MSEs) support

17. Activities not otherwise defined or covered under this G-IEE

18 Categorically Excluded activities are not always low climate risk

4.13 SUMMARY OF IMPLEMENTATION CONDITIONS

This G-IEE includes a global analysis of OTI programs for potential environmental impact and climate risks, and it provides a process for the development of program-specific analysis for field implementation tailored to OTI’s adaptive operating model.

G-IEE IMPLEMENTATION CONDITIONS (APPLICABLE TO ALL OTI PROGRAMS)

This section…