Attachment J.3 PIEE Asia 20-042.pdf

ASIA AND OAPA EMERGING THREATS PIEE

ASIA BUREAU AND OFFICE OF AFGHANISTAN AND

PAKISTAN AFFAIRS (OAPA) PROGRAMMATIC INITIAL

ENVIRONMENTAL EXAMINATION (PIEE) – EMERGING

THREATS (COVID 19)

Project/Activity Name: EMERGING THREATS (COVID-19)

Geographic Location(s) (Country/Region): ASIA AND OAPA

Implementation Start/End Date (FY or M/D/Y): APRIL 2020- March 2022

Solicitation/Contract/Award Number(s): Multiple

Implementing Partner(s): Multiple

Bureau Tracking ID: ASIA & OAPA COVID P-IEE

Tracking ID of Related RCE/IEE (if any): E&E Bureau 2020-EE-005, Middle East 2020-

ME-024, RFS-20-02-004

ORGANIZATIONAL/ADMINISTRATIVE DATA:

Implementing Operating Unit(s): ASIA AND OAPA Missions

Other Affected Operating Unit(s): GH

Lead BEO Bureau: ASIA with OAPA

Funding Account(s) (if available): N/A

Prepared by and Date: ASIA and OAPA; APRIL 2020

ENVIRONMENTAL COMPLIANCE REVIEW DATA:

Analysis Type: IEE

Environmental Determination(s): Categorical Exclusion and Negative Determination with Conditions

IEE Expiration Date (if applicable): September 2022

Additional Analyses/Reporting Required: Operating Unit-level Memorandum to File (MTF)

Climate Risks Identified (#): Low ___#___ Moderate ___#___ High ___#___

Asia 20-042 about:blank about:blank about:blank

(Programmatic) Pesticides Evaluation Report and Safer Use Action Plan (P)PERSUAP

FAA 118/119 Report

Other USG and USAID Statutory Requirements as Applicable and Warranted in view of “emergency” type operation

Provide reference to Climate Risk and Vulnerability Analysis for (Regional) Mission-level CDCS

Mission-level Programmatic PERSUAP to be amended for additional pesticides and/or for disinfectants by Memorandum to File, if adding those approved by US EPA and US CDC

Mission-level FAA 118/119 report for CDCS should be consulted to review actions needed to protect forests, natural habitats, eco-systems and to stop wild-life exploitation and trafficking in order to avoid and prevent root causes for current and potentially (re-) emerging pandemics and spread of dangerous virus and other diseases

Mandatory Gender as well as other relevant analysis of water, natural resources management status at a country level as completed at the Mission level for CDCS or PAD shall be utilized as appropriate to satisfy mandatory provisions at an activity level; any specific related waivers applicable and approved to a specific country or Mission’s operation shall be noted in MTF

SUMMARY OF FINDINGS

PURPOSE AND SCOPE

This COVID-19 Programmatic Initial Environmental Evaluation (COVID-19 PIEE) is intended to provide Asia and OAPA Missions or Regional Operating Units (OUs) with preliminary analysis and recommendations to inform and facilitate their compliance with the Agency’s mandatory Environmental Procedures (see 22 CFR 216 and ADS 204, and relevant Agency Strategies and ADS) as they initiate new interventions in response to the COVID-19 pandemic. The intent of the document is to facilitate and streamline the coverage of new interventions in response to COVID-19. This regional document captures the generally-applicable analysis of potential environmental and social, including occupational health and safety (OHS), risks and impacts, and recommended monitoring, mitigation, and reporting that can be utilized as a resource for further analysis at the Mission- or Regional OU-level.

https://www.usaid.gov/environmental-procedures https://www.usaid.gov/environmental-procedures/laws-regulations-policies/22-cfr-216 https://www.usaid.gov/ads/policy/200/204

This PIEE anticipates that Missions or Regional OU’s will document the application of appropriate safeguards to their activities using Memoranda to the File (MTF). For their OU’s COVID-19 response interventions, A/CORs, assisted by Mission Environmental Officers (MEOs) and Climate Integration Leads (CILs) or Regional OU equivalents, will develop for approval MTFs using safeguards information contained herein. The Asia and OAPA Bureau Environmental Officers (Asia BEO and OAPA BEO) and Regional Environmental Advisors for Central and South Asia and Office of Afghanistan and Pakistan Affairs/Officer for South East Asia and Pacific Islands (REA SCA & OAPA) and for East Asia and Pacific Islands (REA EAP) are available for consultation.

While this document recommends environmental determinations (and, as appropriate monitoring, mitigation, and reporting requirements), it is not a decisional document. USAID’s Environmental Procedures require that a Mission Director or Regional OU equivalent proposes an environmental determination for the OU’s planned activities. The Mission or Regional OU’s MTF can incorporate the analysis and recommendations of this COVID-19 PIEE by reference and thereby operationalize them in advance of an irreversible obligation of funding. Time and effort will be saved by OUs not needing to repeat the analysis found in this COVID-19 PIEE.

These MTFs can, in most cases, be very brief. It is the intent that each MTF will:

● Recommend the necessary environmental determination for new awards being issued expressly for COVID-19 response actions; and

● Avoid the need to amend existing IEEs/RCEs for ongoing mechanisms at the Mission-level to which COVID-19 response interventions are being added.

If they prefer Missions or Regional OUs could document the application of appropriate safeguards to their activities using a supplemental initial environmental examination (SIEE).

LIMITATIONS OF THIS COVID-19 PIEE

This COVID-19 PIEE fulfills the narrowly defined task of helping to meet the environmental impact assessment requirements of the Agency’s Environmental Procedures. It does not provide official guidance on how USAID programs and Missions should respond to COVID-19.

USAID COVID-19 Task Force is the source of such official guidance.

REVISIONS

Changes in the scope and nature of approved activities, life of project (LOP) duration, and LOP funding level, approved herein, shall be through an amendment to this PIEE.

Changes in the scope and nature of approved activities, LOP duration and LOP funding level, approved in Mission- and Regional OU-level MTFs, shall be through an amendment to the original MTF. If these types of changes will likewise require an amendment if SIEEs are involved.

ENVIRONMENTAL DETERMINATION FOR ACTIVITY GROUPS AND TYPES

This COVID-19 PIEE’s analysis addresses the two broad activity groups and eight types that could be expected as near-term interventions for COVID-19 response and that fall under the following environmental determinations:

Group A. Categorical Exclusion: Communications, outreach, analysis, planning, and other actions that typically have minimal, if any, impacts on the environment or human health and safety. That is, when there is no use of regulated commodities and PPE in a class setting and when there is no direct contact with potentially affected people and when such activities are conducted through videoconferencing without gathering of any number of people in situ.

Group B. Negative Determination with Conditions:

1. Laboratory or research strengthening (e.g., vaccine research, equipment purchases, operation of laboratories, procurement and supply management, waste management, including disposal of personal protective equipment (PPE))

2. Support to formal, informal, or temporary healthcare facilities and systems (e.g., transportation and provision of equipment, operation of facilities, procurement and supply management, support for waste management, including disposal of PPE);

3. Support for use of disinfectants/germicides (pesticides;)

4. Water, Sanitation, and Hygiene (WASH) (e.g. construction/rehabilitation of water points, hand washing stations, provision of soap and hygiene kits to households);

5. Food security (e.g. food storage and distribution);

6. Small-scale construction and rehabilitation (e.g., installation of mobile units, latrine construction, temporary hospital/health post construction);

7. Small and medium enterprises in support of COVID-19 response (e.g. personal protective equipment (PPE) production, sanitizer production).

This list of activity groups and types is illustrative only. Other activities undertaken in response to COVID-19 that are not addressed in this COVID-19 PIEE can be addressed by the subject Mission or Regional OU through its MTF.

Missions or Regional OUs should timely seek advice from a cognizant USAID environmental safeguards officer, e.g., MEO, CIL, REA/SCA & OAPA, REA/EAP, BEO/Asia, or BEO/OAPA, when the scope and nature of proposed activities may pose risk of significant adverse environmental or social impacts and, therefore, a Positive Determination (requiring an environmental assessment) would be the more appropriate threshold decision. This revised decision will be documented and approved in an initial environmental examination (IEE) that would supplemental to the PIEE.

A Categorical Exclusion is recommended, in accordance with 22 CFR 216.2(c)(2.), for types of activities noted above in Group A. (of the Environmental Determination for Activity Groups and Types section) when there is no direct contact with potentially affected people and when such activities are conducted through videoconferencing without gathering of any number of people in situ without associated activities that are likely to have adverse environment, health or safety impacts.

A Negative Determination with Conditions is recommended for activity types in Group B that will be implemented in response to COVID-19, i.e., those that are not communications, outreach, analysis, planning, or other actions that can be done remotely or with adequate social distancing. This PIEE recommends that categorical exclusions are not the appropriate determination for some activities that would typically qualify (for categorical exclusion) because COVID-19 is a disease that is inherently going to affect every activity and pose risks to human health and the environment. Thus, even normal Categorical Exclusions activities will have components requiring mitigation of very infectious disease effects. Even education, technical assistance, or programs intended to develop the capability of recipient countries to engage in development planning, if delivered in a group setting, will require implementation and monitoring of safeguards to reduce workplace exposure and infectious agent transmission.

Pursuant to 22 CFR 216.2(b)(1)(ii), the COVID-19 response activities covered herein do not qualify for an exemption from environmental examination without Assistant Administrator or Administrator review and clearance, and Council on Environmental Quality consultation.

CONDITIONS OF THIS PIEE

1. As a streamlined mechanism to meet environmental compliance requirements, USAID Missions are instructed to operationalize this COVID-19 PIEE through the development, by Activity Teams, A/CORs, MEOs, CILs, or Regional OU equivalent of MTFs for Mission-specific COVID-19 response activities and submission of MTFs for BEO/Asia and BEO/OAPA concurrence.

2. This PIEE provides a preliminary analysis of environmental impacts and recommends a range of suitable environmental impact mitigation measures (summarized in Section 3 and 5 and detailed in Annex 2 and 3). The MTFs prepared by Asia and OAPA Missions or Regional OUs will direct their IPs to develop and implement Environmental Mitigation and Monitoring Plans (EMMPs). The MTFs shall direct IPs to incorporate climate risk screening (ADS 201mal1) and construction risk management (using the guidance and tool established in ADS 201maw2 and ADS 303maw) at an activity level and, as appropriate, pursue mitigation, monitoring, and reporting related to these risks.

3. If further analysis of an activity’s scope, scale and nature reveals the likelihood of significant adverse environmental or social impacts, then a Positive Determination (requiring an environmental assessment) shall be the appropriate threshold decision. This revised decision shall be documented and approved in a supplemental (to this PIEE) Initial Environmental Examination (SIEE) approved by a cognizant Mission Director or Regional OU equivalent and concurred to by a cognizant BEO.

CLIMATE RISK MANAGEMENT

1 https://www.usaid.gov/sites/default/files/documents/1868/201mal_042817.pdf and https://www.climatelinks.org/tools 2 https://www.usaid.gov/sites/default/files/documents/1865/201maw.pdf and https://docs.google.com/forms/d/e/1FAIpQLSfauPIQT5N4U-16VRfq4d7xChO8gqVP5T313OHco-yJ2eKPKg/viewform and https://www.usaid.gov/sites/default/files/documents/1868/303maw.pdf https://www.usaid.gov/sites/default/files/documents/1868/201mal_042817.pdf https://www.climatelinks.org/tools https://www.usaid.gov/sites/default/files/documents/1865/201maw.pdf https://docs.google.com/forms/d/e/1FAIpQLSfauPIQT5N4U-16VRfq4d7xChO8gqVP5T313OHco-yJ2eKPKg/viewform https://docs.google.com/forms/d/e/1FAIpQLSfauPIQT5N4U-16VRfq4d7xChO8gqVP5T313OHco-yJ2eKPKg/viewform https://www.usaid.gov/sites/default/files/documents/1868/303maw.pdf

Climate Risk Management screening was not completed for this COVID-19 PIEE and will be required for COVID-19 MTFs in Asia Missions or Regional OU for activities outlined in B. of the Environmental Determination of Activity Groups and Types section above. It is expected that many COVID-19 response activities will be implemented through existing projects, for which climate risk screening has been completed. In these cases, additional climate risk screening will not be required.

However, for new COVID-19 response activities that will continue beyond the immediate pandemic response, CRM screening should be conducted. Within one year of the Mission’s COVID-19 MTF approval date, Asia and OAPA Missions shall evaluate their COVID-19 response actions and conduct CRM screening for those: 1) NOT already screened, and 2) expected to continue for another year or more. Please see Annex 6 for guidance and information on CRM and the connection between climate and COVID-19.

https://docs.google.com/document/d/1MQZ2-xs8kxAheXryD617gKGXGh_irnE7/edit#bookmark=id.17dp8vu https://docs.google.com/document/d/1MQZ2-xs8kxAheXryD617gKGXGh_irnE7/edit#bookmark=id.17dp8vu https://docs.google.com/document/d/1MQZ2-xs8kxAheXryD617gKGXGh_irnE7/edit#bookmark=id.17dp8vu https://docs.google.com/document/d/1MQZ2-xs8kxAheXryD617gKGXGh_irnE7/edit#bookmark=id.17dp8vu https://docs.google.com/document/d/1MQZ2-xs8kxAheXryD617gKGXGh_irnE7/edit#bookmark=id.17dp8vu https://docs.google.com/document/d/1MQZ2-xs8kxAheXryD617gKGXGh_irnE7/edit#bookmark=id.17dp8vu https://docs.google.com/document/d/1MQZ2-xs8kxAheXryD617gKGXGh_irnE7/edit#bookmark=id.17dp8vu

INITIAL ENVIRONMENTAL EXAMINATION

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE OF THE PROGRAMMATIC IEE

This COVID-19 Programmatic Initial Environmental Evaluation (COVID-19 PIEE) is intended to provide Asia and OAPA Missions and Regional OU with preliminary analysis and recommendations to inform and facilitate their compliance with the Agency’s mandatory Environmental Procedures (see 22 CFR 216 and ADS 204) as they initiate new interventions in response to the COVID-19 pandemic. To ensure cross-Agency coordination and a consistent approach, this PIEE was developed in consultation with the Global Health BEO, Acting Agency Environmental Coordinator, and E3’s General Counsel.

This COVID-19 PIEE is a critical element of the mandatory environmental review and compliance process that USAID follows to achieve environmentally sound design and implementation. Addition details about the purpose of this COVID-19 PIEE include:

1. The PIEE will streamline environmental impact assessment of new interventions in response to COVID-19 through a single Asia Bureau and OAPA programmatic analysis and direct development and approval of MTFs, using safeguards information contained herein, for each Mission or Regional OU’s COVID-19 response intervention.

2. For ongoing activities already covered by an environmental impact assessment document (IEE or Request for Categorical Exclusion (RCE)) that will be asked to initiate new COVID- 19 response interventions, this COVID-19 PIEE is intended to avoid the need to amend those existing IEEs/RCEs. Instead, the intent is that the Mission or Regional OU’s MTF (supplemental to this COVID-19 PIEE) will ensure these newly-added interventions comply with USAID’s legal safeguards requirements. The MTF shall include identification of new elements needed in an implementing partner’s (IP) Environmental Mitigation and Monitoring Plan (EMMP;) for activities with approved Categorical Exclusion, preparation of an EMMP is not required. EMMP shall be approved by A/COR and MEO and CIL or Regional OU equivalent.

3. For COVID-19 response actions planned through new awards, not yet covered by an IEE or RCE, the Mission or Regional OU’s MTF shall align new activities with the Environmental Determination (see Environmental Determinations for Activity Groups and Types sections A and B above) for those awards’ COVID-19 response actions. That alignment shall be based upon analysis and recommendations in this PIEE. To the extent those awards are exclusively focused on the COVID-19 response, the MTF will suffice as documentation of compliance with USAID’s legal safeguards requirements.

4. This COVID-19 PIEE is not a decision document. While this document recommends environmental determinations (and, as appropriate monitoring, mitigation, and reporting requirements), USAID’s Environmental Procedures require that a Mission Director or Regional OU equivalent proposes an environmental determination for the OU’s planned activities. The Mission or Regional OU’s MTF can incorporate the analysis and recommendations of this COVID-19 PIEE by reference and thereby operationalize them in advance of an irreversible obligation of funding. Time and effort will be saved by OUs not needing to repeat the analysis found in this COVID-19 PIEE.

This COVID-19 PIEE provides an examination of the potential environmental, OHS, and social risks and impacts from activities expected to be a part of USAID’s COVID-19 responses, as well as recommended environmental determinations and appropriate mitigating, monitoring and reporting requirements for those activities. The document’s analysis addresses a list of illustrative activities. Other activities undertaken in response to COVID-19 that are not addressed in this COVID-19 PIEE can be addressed by the Mission or Regional Office through their MTF and/or a Supplemental IEE, when and if a Positive Threshold Decision is expected and an environmental assessment process will be triggered.

MTFs

Each Asia and OAPA Mission or Regional OU that intends to initiate a response to the COVID- 19 pandemic should in consultation with MEO, cognizant REA and BEO, prepare MTF, either OU-wide or activity-specific, as appropriate and most effective in view of the scope, scale and nature of projects’ portfolio, following the template included in this COVID-19 PIEE. The MTF shall:

● Identify the expected COVID-19 response activities;

● Describe additional mitigating, monitoring and reporting actions that IPs shall be asked to undertake and to include in their EMMPs;

● Describe the new activities being initiated in response to COVID-19 that are not covered by a current OU-level IEE or RCE, and recommend threshold determinations and mitigating, monitoring and reporting measures for those activities. The MTF shall be the document that provides the mandatory environmental compliance review and environmental determination decision(s) for those activities.

● In rare cases, not be necessary for COVID-19 response interventions. In cases where an OU representative, e.g., Agreement/Contracting Officer’s Representative (AOR/COR) or Mission Environmental Officer (MEO), believes that an already-approved IEE contains adequate human health and environmental protection conditions for the anticipated response, he/she/they will communicate a recommendation to dispense with an MTF to the Regional BEO for a final decision.

This COVID-19 PIEE aims to help OU’s more rapidly and easily respond to the Agency’s mandatory Environmental Procedures, avoiding delays in initiation of COVID-19 response actions and improving their overall effectiveness.

If they prefer, Missions or Regional OUs could document the application of appropriate safeguards to their activities using a supplemental initial environmental examination (SIEE) instead of an MTF.

Other Relevant Guidance

This document must be viewed in the full context of guidance, recommendations, and policy direction being developed and issued by USAID and by partner governments regarding the COVID-19 pandemic. This COVID-19 PIEE references Agency guidance and procedures available at the time of preparation. In preparing their MTFs (or other IEEs, as and/or when warranted) related to their COVID-19 response actions, Mission and Regional OU should remain alert to new guidance, recommendations, and policy that may relate to the design and implementation of those actions.

1.2 INTERVENTION CATEGORIES/ACTIONS

For purposes of this COVID-19 PIEE, USAID’s COVID-19 response is expected to include work in the support areas listed below. This list is illustrative, not exhaustive; any response activities not found in this list shall be considered in Mission’s or Regional OU’s MTF.

Group A Activity Type:

1. Communications, outreach, analysis, planning, and other actions that typically have no impact on the environment;

Group B Activity Type:

1. Laboratory or research strengthening, including waste management and contaminated personal protective equipment (PPE)

2. Support to formal and informal/temporary healthcare facilities and systems, including waste management and contaminated PPE;

3. Support for use of disinfectants/germicides;

4. Water, Sanitation, and Hygiene (WASH);

5. Food security;

6. Small-scale construction and rehabilitation;

7. Small and medium enterprises in support of COVID-19 response.

1.3 ACTIVITY OVERVIEW

The 2020 COVID-19 pandemic is a new disease that is distinct from other respiratory illnesses.

Although coronavirus and influenza infections may present with similar symptoms, the virus responsible for COVID-19 is different with respect to community spread and severity. There is still much to discover about the disease and its impact in different contexts. Preparedness, readiness, and response actions -- including social distancing -- will continue to be driven by rapidly accumulating scientific and public health knowledge. It is likely that USAID interventions related to COVID-19 will be driven by Agency-wide efforts and Mission-specific interventions in the form of new activities and pivots to existing activities.

On March 18, 2020, the U.S. Government announced the release of $62 million from the Emergency Reserve Fund (ERF) for Contagious Infectious-Disease Outbreaks at USAID to address the pandemic of COVID-19. COVID-19, the disease caused by the novel coronavirus SARS-CoV-2, is at the center of a widespread global pandemic. In responding to the global public health emergency, USAID is working to boost the capacity of laboratories across the developing world in order to ensure future preparedness against this novel coronavirus. USAID has issued a determination to make the funds from the ERF available to combat the increasing health threat in developing countries affected by, or at high-risk of the COVID-19 pandemic.

This funding fulfills the U.S. Department of State’s pledge of up to $100 million for international efforts to combat COVID-19.

Missions and Bureaus, through new and existing mechanisms, may support the development of approaches and tools related to preparedness, readiness, communication, supplies and equipment, training, capacity building, and humanitarian response actions driven by the rapidly accumulating scientific and public health knowledge. To help immediately combat COVID-19, USAID interventions aim to strengthen host governmental and IP COVID-19 preparedness and response to reduce transmission and, to the extent possible, limit the impact of the virus.

USAID, with the support of its partners, is taking steps to organize an effective response to contain and end this outbreak, while protecting staff and partner staff. This effort includes logistics, communication, developing a response plan and - with an unknown time frame - the eventual vaccination strategy.

1.4 ACTIVIY GROUPS AND TYPES

To facilitate the environmental impact evaluation for this COVID IEE, this document has been organized into two primary Activity Groups (A and B) and eight Activity Types. An Activity Type is not an individual, named activity, but instead represents a range of types of predictable and similar activities that will require similar monitoring and mitigation measures.

The COVID-19-specific Activity Groups and Types analyzed in this PIEE are noted in Table 1:

TABLE 1: ILLUSTRATIVE ACTIVITIES

Activity Type A1 – Communications, outreach, analysis, planning

Activity Type B1 – Laboratory or research strengthening

Activity Type B2 – Support to formal and informal/temporary healthcare facilities and systems

Activity Type B3 – Use of disinfectants/germicides

Activity Type B4 – WASH

Activity Type B5 – Food Security

Activity Type B6 - Small Scale Construction and Rehabilitation

Activity Type B7 - Small and medium enterprises in support of COVID-19 response

2.0 BASELINE ENVIRONMENTAL INFORMATION

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL,

CLIMATE, SOCIAL, THREATENED AND ENDANGERED SPECIES)

Within the Asia region, the pandemic context may present complicating factors such as insufficient health care facilities and supplies, differing or confusing government guidance and mandates, and limited capacity to enforce measures to reduce infections (e.g., stay-at-home or quarantine orders). Additionally, Asia has many at-risk populations (e.g., immunocompromised individuals and areas where malnutrition is an issue), therefore potentially exacerbating the demands on the healthcare system. The labor migration common across much of Asia also poses risk of infecting communities far from disease centers (and accompanying healthcare facilities) and increases the risk of reinfection of communities that are recovering from outbreaks. Outbreak scale, populations affected, local conditions and capacity for response, and infrastructure will strongly dictate the types of actions necessary and the scale of USAID’s and other donor’s interventions. It is likely that interventions will take place in healthcare facilities, private homes, schools, and other public and private buildings.

As outbreaks progress, communities may face additional challenges where USAID commonly operates. For example, mandated business closures may result in loss of household income, increased poverty, and food insecurity. In the longer term, as farming and business stop, agricultural productivity could significantly decrease and food insecurity is likely to follow. The longer-term social impacts are still unknown.

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL

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

Because this COVID-19 PIEE addresses Asia, the MTFs shall specify applicable standards, laws, policies, and regulations for each country in relation to the COVID-19 outbreak. During the pandemic, standards can quickly evolve, and therefore, local officials should be consulted to identify applicable laws, policies, and regulations at the time of the intervention.

The USG has issued guidance for the US which, as appropriate, can serve as additional reference for USAID activities. Local authorities are also likely to develop their own guidance and protocols. Online information may change as the knowledge about an outbreak evolves, therefore, any references should be regularly consulted.

● CDC’s Cleaning and Disinfection of Households: Interim Recommendations for U.S.

Households with Suspected or Confirmed Coronavirus Disease 2019

● CDC’s Coronavirus Disease Site

● CDC’s How to Protect Yourself

● CDC’s Information for HealthCare Professionals

● CDC’s Information for Laboratories

● CDC’s Guideline for Disinfection and Sterilization in Healthcare Facilities, 2008 Update:

May 2019

● EPA’s List N: Disinfectants for Use Against SARS-CoV-2

● WHO’s Country & Technical Guidance - Coronavirus disease (COVID-19) https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/cleaning-disinfection.html https://www.cdc.gov/coronavirus/2019-ncov/index.html https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/prevention.html https://www.cdc.gov/coronavirus/2019-ncov/hcp/index.html https://www.cdc.gov/coronavirus/2019-nCoV/lab/index.html https://www.cdc.gov/infectioncontrol/pdf/guidelines/disinfection-guidelines-H.pdf https://www.usaid.gov/sites/default/files/documents/1864/FINAL_HCW_SEG_508_12.02.19.pdf https://www.usaid.gov/sites/default/files/documents/1864/FINAL_HCW_SEG_508_12.02.19.pdf https://www.usaid.gov/sites/default/files/documents/1864/FINAL_HCW_SEG_508_12.02.19.pdf https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2 https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL IMPACT

Each of the activities in this PIEE are evaluated for the potential direct, indirect, and cumulative environmental and social (i.e., health and well-being) impacts. Activities are generally associated with those taking place at health facilities, warehouses, in offices, and in transport as well as the natural environment when related to community disinfection waste management, WASH provision or construction.

In general, the anticipated environmental impacts of COVID-19 response actions include the following:

Human (occupational) health and safety risks and impacts exist from:

● Use and waste management of toxic chemicals (which may be pesticides in accordance with US EPA) used in laboratories;

● Disposal of PPE

● Exposure to expired or unusable commodities and other healthcare wastes accessed by the community through scavenging or inappropriate disposal;

● Fumigation of food commodities;

● Use of disinfectants/germicides (aka pesticides) in health facilities, businesses, public spaces, and households;

● Occupational safety of construction, laboratory, healthcare workers, and during Small and Medium Enterprise (SME) production activities; and

● Exposure to COVID-19 at gathering, informational sessions, and during essential work.

Environmental and social impacts exist from:

● Introduction of pharmaceutical and other hazardous waste into the environment;

● Use of disinfectants and release to the environment during ULV fogging and surface cleaning;

● Associated with small scale construction such as solid waste, ground- and surface-water contamination from poorly designed water supply and sanitation systems; and

● Associated with SME production activities.

The potential environmental impacts of the activity types considered in this COVID-19 PIEE are described in detail in Annex 2 and provide a preliminary analysis for Missions and Regional OUs to utilize in preparing their MTFs or SIEEs.

4.0 ENVIRONMENTAL DETERMINATIONS

A Categorical Exclusion is recommended for activities outlined in Group A (See Section 1.4 Activity Groups and Types) when there is no direct contact with potentially affected people and when such activities are conducted through videoconferencing without gathering of any number of people in situ.

A Negative Determination with Conditions is recommended for activities outlined in Group B (See Section 1.4 Activity Groups and Types) implemented in response to COVID-19. No categorical exclusions are applicable to these activities because even the implementation of activities that would typically qualify for a Categorical Exclusion, such as laboratory or research strengthening, presents the risk of COVID-19 transmission if the implementation of those activities would congregate people. As appropriate a negative determination with conditions will apply to Group A activities, such as communications, outreach, analysis, and planning, if the implementation of those activities would congregate people.

Pursuant to 22 CFR 216.2(b)(1)(ii), the COVID-19 response activities covered herein do not qualify for an Exemption from environmental examination without Assistant Administrator or Administrator review and clearance, and Council on Environmental Quality consultation. As noted in ADS 204, the International Disaster Assistance (IDA) Exemption applies only to IDA-funded activities, or non-IDA-funded activities that meet ALL of the criteria as described in ADS

204.3.10 c 1-4. The Agency is conducting proactive advance planning, and therefore, ALL of the non-IDA Exemption criteria do not apply, i.e., “This (Exemption) does not include situations in which the need for the activity was foreseeable and has become urgent merely as a result of the Agency’s lack of advance planning.”

5.0 CONDITIONS AND MITIGATION MEASURES

5.1 CONDITIONS

The environmental determinations in this COVID-19 PIEE are contingent upon full implementation of the following general implementation and monitoring requirements, as well as ADS 204 and other relevant requirements.

● USAID Missions shall operationalize this COVID-19 PIEE through the development and submission for BEO/Asia and BEO/OAPA concurrence of MTF for Mission- or Regional Office specific COVID-19 response activities.

● This PIEE provides a preliminary analysis of environmental and social impacts and recommends a range of risk mitigation measures (summarized in Section 3 and 5 and detailed in Annex 2 and 3). With reference to this COVID-19 PIEE, the MTFs prepared by Asia and OAPA Missions and Regional OU shall direct their IPs to develop and implement an EMMP based on those measures.

General Conditions Recommended for COVID-19 MTFs

Activities shall at a minimum include the following conditions:

● Interventions must build awareness, circulate truthful and verified information, providing and requiring training and capacity building around best environmental and health and safety practices in the context of COVID-19 pandemic;

● Follow Agency and international guidelines for COVID-19 response (see Section 2.2 for examples);

● Ensure access to technical expertise for implementing sound environmental and health and safety practices for COVID-19 activities;

● Comply with relevant host country and international standards and regulations; and

● Develop and implement EMMPs and planning documents for actions involving actions with direct environmental (including OHS) or social impacts such as drinking water, medical waste, disinfection materials, construction, etc.

https://www.usaid.gov/sites/default/files/documents/1864/FINAL_HCW_SEG_508_12.02.19.pdf https://www.usaid.gov/sites/default/files/documents/1864/FINAL_HCW_SEG_508_12.02.19.pdf

ANNEXES

1. Memorandum to the File Template

2. Illustrative Environmental Impacts of Activities

3. Illustrative Mitigation Measures for Use in SIEEs

4. Approved Disinfectants and the Pesticide Procedures Analysis

5. Practical Guidance for the Use of Disinfectants

6. Climate Risk Management

ANNEX 1: MEMORANDUM TO THE FILE TEMPLATE

SUPPLEMENTAL MEMORANDUM TO THE FILE TEMPLATE

INSTRUCTIONS

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

Background:

The purpose of the Memorandum to the File (MTF) is to provide a focused environmental analysis for activities and interventions analyzed in the (Coronavirus Disease 2019) COVID-19 Programmatic IEE (COVID-19 PIEE). This PIEE/MTF process is intended to streamline the coverage of new interventions in response to COVID-19 through the identification of foreseeable impacts and prescribed mitigation measures without the need for each mission or operating unit to develop the analysis independently.

This template is used for:

1. Ongoing activities already covered by an environmental compliance document (Initial Environmental Examination [IEE] or Request for Categorical Exclusion [RCE]) that will incorporate new COVID-19 response interventions

2. COVID-19 response actions planned through new awards not yet covered by an IEE or RCE, the Mission’s or Regional Office’s MTF will provide the necessary threshold decision for those awards’ COVID-19 response actions, based upon the analysis and recommendations in this PIEE. To the extent those awards are exclusively focused on COVID-19 response, the MTF should suffice to provide them environmental compliance coverage.

How to use this template:

1. The first page is standard metadata

2. All headings and existing text are standard.

3. Highlighted text may be updated and/or deleted as appropriate. Please remove all highlighting as you finalize the document.

4. Be sure no Personally Identifiable Information (PII) information is contained within the document prior to submitting for BEO approval.

5. Delete this page as you finalize this document.

Reminder: Mission Environmental Officers, Regional Environmental Officers, and Bureau Environmental Officers are resources for USAID staff developing projects and compliance documents. Please engage them early and often. Additional guidance and help is also available at https://www.usaid.gov/environmental-procedures.

USAID’s Environmental Compliance Database of approved 22 CFR 216 documentation provides examples of approved IEEs and other environmental compliance documents, which may assist with language for similar projects.

https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit https://www.usaid.gov/environmental-procedures http://gemini.info.usaid.gov/egat/envcomp/

BUREAU/MISSION/PROJECT

MTF TEMPLATE VERSION 1.0

MEMORANDUM TO THE FILE

PROJECT/ACTIVITY DATA

Project/Activity Name: COVID-19 Response Geographic Location(s) (Country/Region):

Implementation Start/End Date (FY or M/D/Y):

If Amended, specify New End Date:

Solicitation/Contract/Award Number(s):

Implementing Partner(s):

Bureau Tracking ID:

Tracking ID of related Programmatic IEE:

Tracking ID of Other, Related Analyses:

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

Other Affected Operating Unit(s):

Lead BEO Bureau:

Funding Account(s) (if available):

Original Funding Amount:

If Amended, specify funding amount:

If Amended, specify new funding total:

Prepared by:

Date Prepared:

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: ☐Environmental Examination ☐Deferral Environmental Determination(s): ☐Categorical Exclusion(s)

☐Negative ☐Positive ☐Deferred (per 22 CFR 216.3(a)(7)(iv)

PIEE/IEE Expiration Date (if applicable):

Additional Analyses/Reporting Required: ☐EMMP/EMMR Climate Risks Identified (#): Low ___#___ Moderate ___#___ High ___#___ Climate Risks Addressed (#): Low ___#___ Moderate ___#___ High ___#___ about:blank

BUREAU/MISSION/PROJECT

MTF TEMPLATE VERSION 1.0

USAID APPROVAL OF MEMORANDUM TO THE FILE:

Bureau Tracking ID: ______________________

Clearance:

[NAME], Mission Environmental Officer/Climate Integration Lead

[as appropriate] Date

Clearance:

[NAME], Regional Environmental Advisor [as appropriate] Date

Clearance:

[NAME], Regional Legal Officer [as appropriate] Date

Concurrence:

[NAME}, Asia or OAPA Bureau Environmental Officer [required] Date

DISTRIBUTION:

Project file; MEO tracking, OAA, RLO

MEMORANDUM TO THE FILE (CONSULT BEO

FOR UPDATED FORM)

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE OF THE MEMORANDUM TO THE FILE

This memorandum to the file (MTF) responds to the (Coronavirus Disease 2019 (COVID-19) Programmatic Initial Environmental Evaluation (COVID-19 PIEE) and is intended to ensure compliance with the Agency’s mandatory Environmental Procedures (see 22 CFR 216 and ADS

204) as [OPERATING UNIT] initiates new interventions in response to the COVID-19 pandemic.

It is the intent that this MTF will:

● Recommends the necessary threshold decision for new awards being issued expressly for COVID-19 response actions; and

● Avoid the need to amend existing IEEs/RCEs for ongoing mechanisms at the Mission- or Reginal Office-level to which COVID-19 response interventions are being added.

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

This MTF builds on the COVID-19 PIEE and provides further details based on additional project/activity design and country specific information. Potential environmental impacts should be addressed through formal environmental mitigation and monitoring plans (EMMPs) and/or other measures as described in Section 5.

This MTF is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound design and implementation.

1.2 PROJECT/ACTIVITY OVERVIEW

This MTF calls upon the analysis presented in the COVID-19 PIEE for the following activity types that could be expected as near-term interventions for COVID-19 responses:

[NOTE TO MISSIONS OR REGIONAL OU: REMOVE ANY ACTIVITY TYPE THAT WILL NOT

BE IMPLEMENTED THROUGH THIS MTF]

● Communications, outreach, analysis, planning, and other actions that typically have no impact on the environment.

● Laboratory or research strengthening (e.g., vaccine research, equipment purchases, operation of laboratories, procurement and supply management, waste management, https://www.usaid.gov/our_work/environment/compliance/22cfr216 https://www.usaid.gov/ads/policy/200/201mal https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw including contaminated personal protective equipment (PPE))

● Support to formal and informal/temporary healthcare facilities and systems (e.g., provision of equipment, operation of facilities, procurement and supply management, support for waste management, including contaminated PPE);

● Support for use of disinfectants/germicides;

● Water, Sanitation and Hygiene (WASH) (e.g. provision of soap and hygiene kits to households);

● Food security (e.g. food distribution);

● Small-scale construction and rehabilitation (e.g., installation of mobile units, latrine construction, temporary hospital/health post construction);

● Small and medium enterprises in support of COVID-19 response (e.g. PPE production, sanitizer production).

This list is representative, not exhaustive. Other activities undertaken in response to COVID-19 that are not found addressed in the COVID-19 PIEE will be addressed in this MTF.

1.3 PROJECT/ACTIVITY DESCRIPTION

Concise narrative of actions/interventions added for COVID-19 response

TABLE 2: LIST OF Activity Types/Interventions

Activity Type/Intervention Activity Type 1:

Intervention 1.1:

Intervention 1.2:

Activity Type 2:

Intervention 2.1:

Intervention 2.2:

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

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:

https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.1y810tw https://www.usaid.gov/sites/default/files/documents/1865/201maw.pdf

2.0 BASELINE ENVIRONMENTAL INFORMATION

In development of this MTF, refer back to the COVID-19 PIEE for stated expectations for what is to be detailed in this country- or regional- level MTF. This section should describe the environmental context of the development challenge relevant to the country/location and nature of activities to be implemented. Avoid providing extraneous details. Applicable laws and related international agreements relevant to the activity should be provided, ideally with hyperlinks for more information. Only provide what will be useful and relevant for implementing partners to ensure environmental sound design and workplans.

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL,

CLIMATE, SOCIAL, THREATENED AND ENDANGERED SPECIES)

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL

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

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS

APPROPRIATE)

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

Note to Preparer: This section should provide a list of the activity types and defined or illustrative actions that will be implemented under this MTF. Analysis about many activity types can be found in the COVID- 19 PIEE. Activity types that are not provided in the COVID-19 PIEE should have an analysis of environmental impact here.

PROJECT/ACTIVITY 1: TITLE XXX

TABLE 3A. POTENTIAL IMPACTS – ACTIVITY TYPES/INTERVENTIONS

Activity Type/Intervention Potential environmental and social impacts Activity Type 1:

Intervention 1.1:

Intervention 1.2:

[Add rows as needed]

[Add narratives and summary tables as needed for additional project/activity components.]

4.0 ENVIRONMENTAL DETERMINATIONS

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS

A Categorical Exclusion is recommended, in accordance with 22 CFR 216.2(c)(2.), for communications, outreach, analysis, planning activities when there is no direct contact with potentially affected people and when such activities are conducted through videoconferencing without gathering of any number of people in situ.

A Negative Determination with Conditions is recommended for all other activity types implemented in response to COVID-19.

Pursuant to 22 CFR 216.2(b)(1)(ii), these activities do not qualify for an Exemption from environmental examination without Assistant Administrator or Administrator clearance and Council on Environmental Quality consultation.

4.2 CLIMATE RISK MANAGEMENT

Climate Risk Management (CRM) screening was not completed for this COVID-19 PIEE and is not required for COVID-19 MTFs in ASIA or OAPA operating units (OU). The COVID-19 response meets the criteria for exemption from CRM screening per ADS Reference 201mal because this urgent, short-term response is a “tailored process for screening contingency programming”. In addition, many of the COVID-19 response actions will be implemented through existing projects and activities that have already undergone CRM screening.

However, for new COVID-19 activities that will continue beyond the immediate pandemic response, CRM screening should be conducted. Within one year of the OU’s COVID-19 MTF final approval date, ASIA or OAPA OUs should evaluate their COVID-19 response actions and conduct CRM screening for those: 1) NOT already screened, and 2) expected to continue for another year or more. Please see Annex 6 for guidance and information on CRM and the connection between climate and COVID-19.

5.0 MITIGATION MEASURES AND CONDITIONS

5.1 MITIGATION MEASURES

Note to Preparer: This section should draw relevant information on mitigation measures from the COVID- 19 PIEE tailored to the activity types covered in this MTF.

The mitigation requirements presented in this section constitute the minimum required based on available information at the time of this COVID-19 PIEE and the environmental analysis in Section 3. To fulfill the requirements of this COVID-19 PIEE — and directly address correlated social and environmental impacts — the IP(s) must implement these mitigation measures. To do so, this COVID-19 PIEE requires that these mitigation requirements be translated into specific, implementable, monitorable mitigation measures via an EMMP, as presented in the MTFs. This COVID-19 PIEE provides example mitigation measures in Annex ## for COVID-19 response actions.

https://www.usaid.gov/ads/policy/200/201mal https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.2iq8gzs https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.2iq8gzs https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.2iq8gzs https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.2iq8gzs https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=id.2iq8gzs https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=kix.w45cl2tttlfv https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=kix.w45cl2tttlfv https://docs.google.com/document/d/1hkdNygA0QEipe8XPMOS1YZljFuCWUcg5/edit#bookmark=kix.w45cl2tttlfv

PROJECT/ACTIVITY

TABLE 5A. SUMMARY OF MITIGATION MEASURES

Activity Type/Intervention Mitigation Measure(s) Activity…