Attachment J.5 LAC-23-177 .docx.pdf
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- Attached to
- Institutional Strengthening of the Government of Peru to implement the National Counternarcotic Policy
- Solicitation number
- 72052724R00002
About this file
This document is a Request for Categorical Exclusion (RCE) for the "Institutional Strengthening of the Government of Peru to implement the National Counternarcotics Policy" activity. The purpose of this activity is to strengthen the capacity of the Government of Peru (GOP) to implement the 2020-2030 National Counternarcotics Policy. The proposed components include improving the management, administrative, and budgetary capacity of GOP agencies; enhancing information systems for effective decision-making; improving DEVIDA's coordination and implementation capacity; and establishing channels for citizen oversight and accountability. The RCE recommends Categorical Exclusions for these activities under 22 CFR 216.2(c)(2) as they have no foreseeable significant direct or indirect adverse effects on the environment. The document also provides a climate risk management summary, confirming that the risks associated with the activity are minimal. USAID will ensure that the environmental compliance requirements are incorporated into the solicitation, award, budget, and work plans.
The related federal contract opportunity is a solicitation for the "Institutional Strengthening of the Government of Peru to implement the National Counternarcotics Policy" activity. USAID is seeking proposals from qualified local entities to provide the required services under a five-year, $10 million Cost-Plus-Fixed-Fee contract. Competition is restricted to local entities, who must demonstrate the capability to perform at least 65% of the services with their own resources. Subcontracting is limited to 35% of the total contract cost.
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REQUEST FOR CATEGORICAL EXCLUSION
PROJECT/ACTIVITY DATA
Project/Activity Name: Institutional Strengthening of the Government of Peru to implement the National Counternarcotics Policy Activity
Geographic Location(s) (Country/Region): Lima, San Martin, Huanuco, Ucayali, Pasco, Junin Amendment (Yes/No), if Yes indicate # (1, 2...): No Implementation Start/End Dates (FY or M/D/Y): FY2024-FY2029
If Amended, specify New End Date: N/A Solicitation/Contract/Award Number(s): N/A (new activity in design) Implementing Partner(s): N/A (new activity in design) Bureau Tracking ID: LAC-23-177 Tracking ID of Related RCE/IEE (if any):
Tracking ID of Other, Related Analyses:
ORGANIZATIONAL/ADMINISTRATIVE DATA
Implementing Operating Unit(s):
(e.g. Mission or Bureau or Office)
USAID/Peru Office of Sustainable Development
Other Affected Operating Unit(s): N/A Lead BEO Bureau: LAC
Funding Operating Unit(s):
(e.g. Mission or Bureau or Office)
USAID/Peru Office of Sustainable Development
Funding Account(s) (if available): DV/2022/2023……..…. $3,090,000
DV/GFSI 2022/2023…..$600,000
Original Funding Amount: $10,000,000 If Amended, specify funding amount: N/A If Amended, specify new funding total: N/A
Prepared by: Fernando De Villena Date Prepared: July 24, 2023
ENVIRONMENTAL COMPLIANCE REVIEW DATA
Analysis Type: XRequest for Categorical Exclusion ☐Deferral
Environmental Determination(s): XCategorical Exclusion(s) ☐Deferred (per 22 CFR 216.3(a)(7)(iv))
RCE Expiration Date (if applicable): N/A Additional Analyses/Reporting Required: N/A Climate Risks Identified (#): Low ______ Moderate ___4___ High ___0___ Climate Risks Addressed (#): Low ______ Moderate ___4___ High ___0___
USAID/PERU OFFICE OF SUSTAINABLE DEVELOPMENT 1
RCE TEMPLATE VERSION 3.1
THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS
PROJECT/ACTIVITY SUMMARY
The purpose of this activity is to strengthen the capacity of the GOP, to implement the 2020-2030 National Counternarcotics Policy (NCNP) to achieve target results. This activity would be a direct Mission award.
ENVIRONMENTAL DETERMINATIONS
Upon approval of this document, the determinations become affirmed, per Agency regulations (22 CFR 216).
TABLE 1: ENVIRONMENTAL DETERMINATIONS
Projects/Activities Categorical Exclusion Citation (if applicable) Deferral1
Project/Activity 1:
Improvement of the management, administrative, and budgetary capacity of GOP agencies related to the
NCNP
§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)
§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings
Project/Activity 2:
Improvement of information systems for an effective decision-making to implement the Counternarcotics Policy
§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)
§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings
§216.2(c)(2)(v) Document and information transfers
Project/Activity 3:
Improvement of DEVIDA’s coordination/articulation capacity as the leading entity to efficiently implement the NCNP
§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)
§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings
Project/Activity 4:
Establishment of channels for citizen oversight and accountability of the Counternarcotics Policy Implementation
§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)
§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings
§216.2(c)(2)(v) Document and information transfers
1 Deferrals must be cleared through an Amendment to this RCE prior to implementation of any deferred activities.
USAID/PERU OFFICE OF SUSTAINABLE DEVELOPMENT 2
https://drive.google.com/file/d/13Nj4yIN766hPI6Ov4mZKTEL35Lb8Favv/view?usp=share_link
CLIMATE RISK MANAGEMENT
The risks associated with the implementation of this activity are minimal due to the intrinsic nature of the activity. This activity will promote the implementation of the National Counternarcotics Policy. See additional information in Section 2.2 and Annex 1.
BEO SPECIFIED CONDITIONS OF APPROVAL
None.
IMPLEMENTATION
In accordance with 22 CFR 216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Section 3 of this RCE and any BEO Specified Conditions of Approval.
USAID/PERU OFFICE OF SUSTAINABLE DEVELOPMENT 3
USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION
PROJECT/ACTIVITY NAME: Institutional Strengthening Government of Peru to implement National Counternarcotics Policy Activity
Bureau Tracking ID: LAC-23-177
Approval: Amy Paro, cleared electronically 08/04/2023 Amy Paro, Mission Director Date
Clearance: Mark Gizzi 07/31/2023 Mark Gizzi, SD Office Director Date
Clearance: Cesar Calmet 07/27/2023 Cesar Calmet, future COR Date
Clearance: Florencia Trama July 31, 2023 Florencia Trama, Mission Environmental Officer Date
Clearance: Diana Shannon, cleared electronically July 31, 2023 Diana Shannon, Regional Environmental Advisor Date
Concurrence: Bethzaida Colon 8/7/2023 Bethzaida Colon, LAC Bureau Environmental Officer Date
DISTRIBUTION: Mission Project Team
USAID/PERU OFFICE OF SUSTAINABLE DEVELOPMENT 4
1.0 PROJECT AND ACTIVITY DESCRIPTION
1.1 PURPOSE OF THE RCE
The purpose of this document is to establish that all proposed projects/activities belong to classes of actions eligible for Categorical Exclusions as set out in Agency regulations (22 CFR 216.2(c)) and that there are no foreseeable significant direct or indirect impacts that would preclude them from receiving a Categorical Exclusion. Upon approval of this document, the Categorical Exclusions are affirmed for the project/activity. This analysis also documents the results of the project/activity level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201 mandatory reference 201mal).
This RCE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation.
1.2 PROJECT/ACTIVITY OVERVIEW
This activity will provide technical assistance to the government of Peru, particularly DEVIDA, to more effectively implement the Counternarcotics Policy.
1.3 PROJECT/ACTIVITY DESCRIPTION
The design team proposes the following components for this activity:
● Improvement of the management, administrative, and budgetary capacity of GOP agencies related to the NCNP
● Improvement of information systems for an effective decision-making to implement the
Counternarcotics Policy
● Improvement of DEVIDA’s coordination/articulation capacity as the leading entity to efficiently implement the NCNP
● Establishment of channels for citizen oversight and accountability of the
Counternarcotics Policy implementation
TABLE 2: DEFINED OR ILLUSTRATIVE PROJECTS/ACTIVITIES AND SUB-ACTIVITIES
Project/Activity 1 — Improvement of the management, administrative, and budgetary capacity of GOP agencies related to the NCNP Project/Activity 2 — Sub-activity 1.1 Improvement of information systems for an effective decision-making to implement the Counternarcotics Policy Project/Activity 3 — Improvement of DEVIDA’s coordination/articulation capacity as the leading entity to efficiently implement the NCNP Project/Activity 4 — Establishment of channels for citizen oversight and accountability of the
Counternarcotics Policy implementation
2.0 ENVIRONMENTAL ANALYSIS
2.1 JUSTIFICATION FOR CATEGORICAL EXCLUSION
USAID/PERU OFFICE OF SUSTAINABLE DEVELOPMENT 5
The activities under the Institutional Strengthening of the Government of Peru to implement the National Counternarcotics Policy Activity are among the classes of actions listed in 22 CFR 216.2(c)(2) and have no foreseeable significant direct or indirect adverse effect on the environment. Therefore, under 22 CFR 216.2(c)(1), neither an IEE nor an EA will be required for these activities. Instead, a Categorical Exclusion is recommended for the projects/activities described above in Section 1.3 as follows:
TABLE 3: RECOMMENDED DETERMINATION FOR CATEGORICAL EXCLUSION
Project/Activity and Sub-Activity #
Recommended Determination for Categorical Exclusion
Project/Activity 1 —
Improvement of the management, administrative, and budgetary capacity of GOP agencies related to the NCNP
§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)
§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings
Project/Activity 2 —
Improvement of information systems for an effective decision-making to implement the Counternarcotics Policy
§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)
§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings
§216.2(c)(2)(v) Document and information transfers
Project/Activity 3 —
Improvement of DEVIDA’s coordination/articulation capacity as the leading entity to efficiently implement the NCNP
§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)
§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings
Project/Activity 4 —
Establishment of channels for citizen oversight and accountability of the Counternarcotics Policy implementation
§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)
§216.2(c)(2)(iii) Analyses, studies, academic or research workshops and meetings
§216.2(c)(2)(v) Document and information transfers
2.2 CLIMATE RISK MANAGEMENT
This section summarizes the methodology used and findings of the CRM Screening (see Annex 1). The project design team, in consultation with the CIL, considered the potential effect of climate risks/stressors on the sustainability of the project (changing precipitation patterns, rising temperature, floods, droughts, fires, landslides, etc.) in addition to the impact of project activities on the climate (increased greenhouse gas emissions, land use changes, etc.).
USAID/PERU OFFICE OF SUSTAINABLE DEVELOPMENT 6
3.0 LIMITATIONS OF THE CATEGORICAL EXCLUSION
The categorical exclusions recommended in this document apply only to projects/activities and sub-activities described herein.
Other projects/activities that may arise must be subject to an environmental analysis and the appropriate documentation prepared and approved, whether it be a new Request for Categorical Exclusion, an amendment, or other type of 22 CFR 216 document.
It is confirmed that the projects/activities described herein do not involve actions normally having a significant effect on the environment, including those described in 22 CFR 216.2(d).
3.1 MANDATORY INCLUSION OF ENVIRONMENTAL COMPLIANCE REQUIREMENTS IN SOLICITATIONS, AWARDS, BUDGETS, AND WORK PLANS
USAID will ensure the environmental compliance requirements are incorporated into solicitations, awards, budgets, and work plans, including relevant limitations of Section 3 above. In addition, climate risk management requirements will also be incorporated.
3.2 GENERAL IMPLEMENTATION & MONITORING REQUIREMENTS (IF APPLICABLE)
USAID will ensure that the following requirements are met:
● Provide briefings for Implementing Partner (IP) on environmental compliance responsibilities
● Ensure integration of compliance responsibilities in prime and sub-awards and grant agreements;
● Ensure compliance with applicable partner country requirements
● Annual review of project activities to ensure that scope is still covered by Categorical Exclusion
ATTACHMENTS
Annex 1: Climate Risk Management Summary Table for Activity
USAID/PERU OFFICE OF SUSTAINABLE DEVELOPMENT 7
Annex 1. Activity Climate Risk Management Summary Table Tasks/Defined or Illustrative Interventions
Climate Risks2 Risk Rating3 How Risks are Addressed4 Opportunities to Strengthen Climate Resilience5
Project/Activity 1 —
Improvement of the management, administrative, and budgetary capacity of GOP agencies related to the
NCNP
Floods, landslides may prevent the delivery of technical assistance
Moderate, especially during rainy season and during El Niño occurrence
Virtual sessions and reschedule in- person sessions. Consider contingency measures like time buffers during work planning to account for climate events
Project/Activity 2 —
Improvement of information systems for an effective decision-making to implement the Counternarcotics Policy
Floods, landslides may prevent the delivery of technical assistance
Moderate, especially during rainy season and during El Niño occurrence
Virtual sessions and reschedule in- person sessions. Consider contingency measures like time buffers during work planning to account for climate events
Project/Activity 3 —
Improvement of DEVIDA’s coordination/articulation capacity as the leading entity to efficiently implement the
NCNP
Floods, landslides may prevent the delivery of technical assistance
Moderate, especially during rainy season and during El Niño occurrence
Virtual sessions and reschedule in- person sessions. Consider contingency measures like time buffers during work planning to account for climate events
Project/Activity 4 —
Establishment of channels for citizen oversight and accountability of the Counternarcotics Policy implementation
Floods, landslides may prevent the delivery of technical assistance
Moderate, especially during rainy season and during El Niño occurrence
Virtual sessions and reschedule in- person sessions. Consider contingency measures like time buffers during work planning to account for climate events
5 Describe opportunities to achieve multiple development objectives by integrating climate resilience or mitigation measures
4 Describe how risks have been addressed in activity design and/or additional steps that will be taken in implementation. If you chose to accept the risk, briefly explain why.
3 Low/Moderate/ High 2 List key risks related to the defined/illustrative interventions identified in the screening and additional assessment.
USAID/PERU OFFICE OF SUSTAINABLE DEVELOPMENT 8
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