Attachment J.9 - IEE Final_Uganda Market Systems Strengthening (MSS) RCE_050720.pdf

REQUEST FOR CATEGORICAL

EXCLUSION

PROJECT/ACTIVITY DATA

Project/Activity Name: Uganda Market Systems Strengthening (MSS) Project RCE: Feed the Future Institutional and Systems Strengthening (ISS) Activity

Amendment (Y/N): N Geographic Location(s) (Country/Region): Uganda/East Africa Implementation Start/End: April 2020 to April 2026 Solicitation/Contract/Award Number: TBD Implementing Partner(s): TBD Tracking ID/link: Uganda MSS Project RCE (FtF ISS Activity) https://ecd.usaid.gov/document.php?doc_id=52708 Tracking ID/link of Related RCE/IEE (if any): Other Associated MSS Project Activities:

Uganda_MSS_IEE_2019-2024_02062019 https://ecd.usaid.gov/document.php?doc_id=51770

Tracking ID/link of Other, Related Analyses: Climate Risk Management for Projects and Activities 10/15/2017

Uganda Climate Vulnerability Assessment Report

Economic assessment of the impacts of climate change in Uganda by CDKN (2015), ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

USAID/Uganda

Funding Operating Unit(s):

(e.g. Mission or Bureau or Office)

USAID/Uganda EG Office – Agriculture Sector, Private Sector

Funding Account(s): Feed the Future - Uganda Funding Amount: $19.500,00 Amendment Funding Amount:

Other Affected Unit(s):

Lead BEO Bureau: Africa Prepared by: USAID/Uganda Private Sector Team; and USAID Uganda

Mission Environmental Officer Date Prepared: January 29th, 2020

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: X Request for Categorical Exclusion https://ecd.usaid.gov/document.php?doc_id=52708 https://ecd.usaid.gov/document.php?doc_id=51770 https://www.usaid.gov/sites/default/files/documents/1868/201mal_042817.pdf https://www.usaid.gov/sites/default/files/documents/1868/201mal_042817.pdf https://www.climatelinks.org/sites/default/files/asset/document/ARCC-Uganda%2520VA-Report.pdf https://cdkn.org/wp-content/uploads/2015/11/UGANDA_Economic-assessment-of-climate-change_WEB.pdf https://cdkn.org/wp-content/uploads/2015/11/UGANDA_Economic-assessment-of-climate-change_WEB.pdf

� Amendment � Deferral

Environmental Determination(s): Categorical Exclusion Categorical Exclusion Expiration Date: September 30, 2023 Additional Analyses/Reporting Required:

Climate Risks Identified (#): Low ___X___ Moderate ______ High ______ Climate Risks Addressed (#): Low ______ Moderate ______ High ______

THRESHOLD DECISION MEMO AND SUMMARY OF FINDINGS

PURPOSE AND SCOPE OF THE REQUEST FOR CATEGORICAL EXCLUSION

The purpose of this Request for Categorical Exclusion (RCE) is to provide threshold determinations in accordance with the requirement of Title 22 of the Code of Federal Regulations (CFR) Part 216, for the Feed the Future Institutional and Systems Strengthening (ISS) activity. This activity is one of USAID Uganda’s activities within the portfolio of activities expected to be implemented under the USAID Market Systems Strengthening Project.

The ISS activity’s purpose is to strengthen the capacity and systems of key Government of Uganda (GOU) ministries, departments, agencies (MDAs), and industry apex organizations to enable them to better fulfill their mandates in order to drive agricultural sector growth.

This RCE covers the ISS activity, which falls under the Market Systems Strengthening PAD currently envisioned by the USAID Uganda Economic Growth Office, to be implemented through April 2026.

Given that a Categorical Exclusion is recommended for this set of activities, it was decided that a Request for Categorical Exclusion, rather than an amendment to the Market Systems Strengthening IEE, was most appropriate.

Additionally, this RCE documents the results of the activity Level- Climate Risk Screening in accordance with the USAID policy (specifically, ADS 201 mandatory reference 201 mal_042817): Climate Risk rating for ISS activities is found to be Low.

PROJECT/ACTIVITY SUMMARY

The ISS activity’s purpose is to strengthen the capacity and systems of key national GOU ministries, departments and agencies and industry apex organizations to enable them better to fulfill their mandates in order to drive agricultural sector growth. The activity will focus on providing different forms of institutional governance and administrative systems technical assistance, strengthening the financial operations, developing and maintaining a capacitated human resource, strengthening the ability to enforce and implement policies, and developing and strengthening vertical and horizontal relationships.

This program was designed using a Statement of Objectives (SOO), not a Statement of Work (SOW).

As such, the activity description is deliberately focused on objectives. As a result, the actions can be surmised, but are not officially prescribed. The type of actions that are generally expected to occur under ISS include:

1. All forms of institutional and human resource technical and management capacity technical assistance. For example, (a) developing the right institutional governance and administrative systems, (b) strengthening financial operations, (c) technical assistance to improve the institutions' ability to collect, analyze and disseminate data that is crucial for the agriculture sector (like climate or weather information), (d) developing and maintaining a capacitated human resource pool (for example, through linking them to the right straining service providers or reviewing their organograms to restructure appropriately) and (e) providing technical assistance to enable them improve their capacity to implement and enforce existing policies.

2. Developing and strengthening vertical and horizontal relationships within and across public and private sector institutions by, for example, strengthening existing platforms or mechanisms and developing appropriate new ones where

ENVIRONMENTAL DETERMINATIONS

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

(22CFR216).

TABLE 1: ENVIRONMENTAL DETERMINATIONS

Activities Categorical Exclusion Citation (if applicable) Activity 1: Institutional and Systems Strengthening Activity

§216.2 (c), 1(i), 2(i) (iii) & (v)

Sub-activity 1.1 Strengthening internal processes of the key MDAs and industry apex organizations to enable them better to fulfill their mandate.

Sub -activity 1.2 Strengthening “structures” or key vertical and horizontal linkages within and among target institutions and with local-level institutions

* BEO approval for the Uganda MSS RCE covers only activities that fall under a categorical exclusion determination. All activities, including subgrants, that have ANY foreseeable potential environmental impacts will require an amendment of this RCE to reclassify the activity as a negative determination.

CLIMATE RISK MANAGEMENT

USAID supports strengthening development outcomes by integrating climate change into Agency programming, learning, policy dialogues and operations. The Automated Directives System (ADS) 201 requires climate risk assessment and management for all new projects and activities across sectors to ensure the effectiveness and sustainability of project and activity objectives in the face of extreme weather and climate events.

Per ADS 201 and the climate risk screening process detailed in the mission’s approved CDCS, climate risk analysis has been conducted for the ISS sub-activities. The analysis established that climate risks are low for all planned interventions. ISS rather presents opportunities to reduce climate risks by including capacity building and establishing of relationships for institutions to better identify and manage climate risks in the agricultural sector.

Per ADS 201 and the climate risk screening process detailed in the mission’s approved CDCS, no further climate risk analysis or action is required for the ISS sub-activities. For detailed climate risk screening for these sub-activities, please refer to Annex 1.

BEO SPECIFIED CONDITIONS OF APPROVAL

N/A

IMPLEMENTATION

In accordance with 22CFR216 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.

Bureau Tracking ID: https://ecd.usaid.gov/document.php?doc_id=52708

05/07/2020 https://ecd.usaid.gov/document.php?doc_id=52708

1.0 PROJECT AND ACTIVITY DESCRIPTION

1.1 PURPOSE AND SCOPE OF RCE

The purpose of this document is to establish that all proposed activities of ISS belong to a class of actions eligible for Categorical Exclusions as set out in Agency regulations (22CFR 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 ISS activities. This analysis also documents the results of the ISS level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201 mandatory reference 201mal). This RCE is a critical element of a mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation.

1.2 PROJECT OVERVIEW

The purpose of the ISS activity is to improve the performance and structures of Government of Uganda (GOU) ministries, departments and agencies (MDAs) and industry apex organizations that are vital to driving inclusive agriculture-led economic growth. To achieve this, the Activity will support selected MDAs and apex industry organizations to improve their internal processes. It will also strengthen structures, i.e., the vertical and horizontal linkages among these organizations and others, so that they work together more effectively to achieve their goals. This is a $19,500,000 5-year activity which will be funded with an initial allocation of $4,000,000 of FY 18 Development Assistance (DA) funds. Subsequent year funding will be allocated to the activity as funds become available.

This program was designed using a Statement of Objectives (SOO), not a Statement of Work (SOW).

As such, the activity description is deliberately focused on objectives. As a result, the actions can be surmised, but are not officially prescribed. The type of actions that are generally expected to occur under ISS include:

1. All forms of institutional and human resource technical and management capacity technical assistance. For example, (a) developing the right institutional governance and administrative systems, (b) strengthening financial operations, (c) technical assistance to improve the institutions' ability to collect, analyze and disseminate data that is crucial for the agriculture sector (like climate or weather information), (d) developing and maintaining a capacitated human resource pool (for example, through linking them to the right straining service providers or reviewing their organograms to restructure appropriately) and (e) providing technical assistance to enable them improve their capacity to implement and enforce existing policies.

2. Developing and strengthening vertical and horizontal relationships within and across public and private sector institutions by, for example, strengthening existing platforms or mechanisms and developing appropriate new ones where they are lacking.

1.3 PROJECT DESCRIPTION

The ISS activity’s purpose is to strengthen the capacity and systems of key national Government of Uganda ministries, departments and agencies and industry apex organizations to enable them better to fulfill their mandates in order to drive agricultural sector growth. The activity will focus on providing different forms of (a) institutional governance and administrative systems technical assistance through supporting development of leadership and management skills, and supporting the development of appropriate management structures, (c) strengthening the financial operations through the development of effective and efficient planning and budgeting cycles and developing clear financial processes, (d) developing and maintaining a capacitated human resource through supporting the development of efficient human resource management systems and supporting human resource capacity assessments and training plans, (e) strengthening the ability to enforce and implement policies through developing strategic action frameworks that identify the respective roles of MDAs and establishing platforms for effective coordination, and (f) developing and strengthening vertical and horizontal relationships by supporting the establishment and strengthening of inter-agency and public-private dialogue and coordination platforms, communication strategies and data sharing networks and processes .Through this support, the MDAs and industry apex organizations will have transparent financial processes, employ skilled human resource, appropriate management and administrative structures and processes as well as updated data. Ultimately, the institutions will effectively deliver services to strengthen the agriculture sector.

2.0 ENVIRONMENTAL ANALYSIS

2.1 JUSTIFICATION FOR CATEGORICAL EXCLUSION

The sub-activities under the ISS activity are among a class of actions listed in 22CFR216.2(c)(2) and have no foreseeable significant direct or indirect adverse effect on the environment. Therefore, under 22CFR216.2(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

Activity and Sub-Activity # Recommended Determination for Categorical Exclusion

Project/Activity 1: Institutional and Systems Strengthening Activity

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

Sub-activity 1.1 Strengthening internal processes of the key MDAs and industry apex organizations to enable them better to fulfill their mandate.

Sub-activity 1.2 Strengthening “structures” or key vertical and horizontal linkages within and among target institutions and with local-level institutions

* BEO approval for the Uganda MSS RCE covers only activities that fall under a categorical exclusion determination. All activities, including subgrants, that have ANY foreseeable potential environmental impacts will require an amendment of this RCE to reclassify the activity as a negative determination.

2.2 CLIMATE RISK MANAGEMENT

ANNEX 1: CLIMATE RISK SCREENING AND MANAGEMENT TOOL FOR INSTITUTIONAL AND SYSTEMS

STRENGTHENING (ISS) ACTIVITY DESIGN

OUTPUT MATRIX: CLIMATE RISKS, OPPORTUNITIES, AND ACTIONS FOR INSTITUTIONAL AND SYSTEMS STRENGTHENING (ISS)

ACTIVITY DESIGN

1.1. (a) Activity Element

1.1. (b) Element description

Specific Activities 1.2: Time frame 1.3: Geo-graphy

2:

Climate Risks*

3: Adaptive Capacity

4: Climate Risk Rating* 5: Opportunities

6.1: Climate Risk Management Options

6.2: How Climate Risks

Are Addressed in the Project*

7: Next Steps for Activity Design*

8:

Accepted Climate Risks*

Institutional capacity building technical assistance

Improving internal processes of key MDAs and industry apex organizations to enable them better to fulfill their mandates in agricultural sector development

Developing the right institutional governance and administrative systems, strengthening the financial operations to ensure transparency and sustainability, developing and maintaining a capacitated human resource pool, strengthening ability to implement and enforce policies

0-10 years National None N/A Low The interventions could include capacity building for institutions to better identify and manage climate risks in the agricultural sector

N/A N/A N/A None

Systems strengthening technical assistance

Strengthening “structures” or key vertical and horizontal linkages between and among institutions for effective coordination .

Developing and strengthening vertical and horizontal relationships between institutions (inter-agency); within institutions (intra-agency); and public-private

0-15 years National None N/A Low Could include establishing relationships to address climate risks in the agricultural sector

N/A N/A N/A None

1.1. (a) Activity Element

1.1. (b) Element description

Specific Activities 1.2: Time frame 1.3: Geo-graphy

2:

Climate Risks*

3: Adaptive Capacity

4: Climate Risk Rating* 5: Opportunities

6.1: Climate Risk Management Options

6.2: How Climate Risks

Are Addressed in the Project*

7: Next Steps for Activity Design*

8:

Accepted Climate Risks* partnerships

3.0 LIMITATIONS OF THE CATEGORICAL EXCLUSION

The categorical exclusions recommended in this document apply only to ISS sub-activities described herein.

Other ISS sub-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 22CFR216 document.

It is confirmed that the ISS described herein do not involve actions normally having a significant effect on the environment, including those described in 22CFR216.2(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

No mitigation measures are required for the ISS activities as all planned interventions are Categorically Excluded under 22 CFR 216 as described above.