BHA_FY23_RFA-IEE_DRC RFSA_Final Draft.pdf

BHA/DRC/RFA IEE 1

INITIAL ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY DATA

Project/Activity Name: USAID Bureau of Humanitarian Assistance (BHA) FY23 Request for Applications (RFA) for Resilience Food Security Activities in the Democratic Republic of the Congo (DRC)

Geographic Location(s) (Country/Region): Kasai, Kasai Central, and Tanganyika Provinces in DRC/East Africa

Amendment (Yes/No) N

Implementation Start/End Date Pre-Award, to be determined upon award(s)

Solicitation/Contract/Award Number(s): To be determined upon award(s)

Implementing Partner(s): To be determined upon award(s)

Link to IEE:

Link of Other, Related Analyses: DRC 118/119, DRC Climate Risk Profile, DRC Programmatic

PERSUAP

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

Bureau of Humanitarian Assistance (BHA)

Funding Operating Unit(s):

(e.g. Mission or Bureau or Office)

Same as above

Other Affected Operating Unit(s): USAID/DRC

Lead BEO Bureau: Humanitarian Assistance

Funding Account(s) (if available): Title II

Original Funding Amount:

Prepared by: Environmental Compliance Support (ECOS) contract

Date Prepared: October 2022

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: ☒Initial Environmental Examination ☐Amendment

Environmental Determination(s): ☐Categorical Exclusion(s)

☒Negative ☒Positive ☒Deferral

IEE Expiration Date (if applicable): 2028, End of Awards

Additional Analyses/Reporting Required: Implementing Partners to develop Supplemental IEEs

Climate Risk Rating for Risks Identified: Low ___X___ Moderate ___X___ High ___X___

THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS

PURPOSE AND SCOPE OF THE INITIAL ENVIRONMENTAL EXAMINATION

https://pdf.usaid.gov/pdf_docs/Pnads946.pdf https://ecd.usaid.gov/document.php?doc_id=55148 https://ecd.usaid.gov/document.php?doc_id=55148 about:blank about:blank

BHA/DRC/RFA IEE 2

The purpose of this RFA-level Initial Environmental Examination (IEE) is to establish environmental compliance procedures and templates1 for future awarded activities under the Bureau for Humanitarian Assistance (BHA)2 Fiscal Year 2023 Request for Application (RFA) for Democratic Republic of the Congo (DRC) Resilience Food Security Activities.

ACTIVITY SUMMARY

As specified in the RFA, these activities will contribute to the achievement of resilience and economic and social development plans while reducing food insecurity in the target countries. This RFA IEE also addresses COVID-19 22 CFR 216 response elements of BHA programming.

ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

The table below summarized the Environmental Determinations and Climate Risk Ratings for activities analyzed in this RFA IEE.

Interventions 22 CFR 216 Environmental Determination Climate Risk Rating

Commodity Fumigation Positive Determination Low, moderate, and high (see CRM table)

Increased use of disinfectants/germicides to minimize COVID-19 transmission

Negative Determination Low

Increased use of PPE and support for PPE production to minimize COVID- 19 transmission

Negative Determination Low and Moderate

Other BHA Activities Deferral for all other BHA Activities, to be assessed in the Supplemental IEE. Activities which previously qualified as a Categorical Exclusion, but now propose a risk to COVID-19, must be classified as a Negative Determination3 until further notice.

Postponed Assessment, Rating to be assessed along with Supplemental IEE analysis

BEO SPECIFIED CONDITIONS OF APPROVAL

1 Word versions of the required templates can be found at a Google drive here.

2 Please note that per USAID’s strategic reorganization, the offices of Bureau of Humanitarian Assistance (BHA) and Foreign

Disaster Assistance (OFDA) have now merged into the Bureau for Humanitarian Assistance.

3 As COVID-19 safety protocols are updated (e.g., social distancing, virus and antibody testing, contact tracing, etc.), this determination may be subject to change.

https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8

BHA/DRC/RFA IEE 3

Condition 1: Applicant to submit Environmental Safeguards Plan.

Condition 2: Awardee to develop Supplemental IEE for Mission and Washington clearance by the end of the R&I year.4

Condition 3: Awardee to develop and align Environmental Mitigation and Monitoring Plan (EMMP) and Climate Risk Management (CRM) with performance M&E systems.

Condition 4: Awardee to submit Environmental Status Reports (ESRs5) annually before the Pipeline Resource Estimate Proposal (PREP). Additional reporting is reflected in the Annual Results Report (ARR).

Condition 5: Awardee to develop an Environmental Assessment for any actions with potential for significant impact to ecological habitats, as determined by USAID.

Condition 6: Awardee to plan for a Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP), which includes for pesticide procurement and/or use (e.g., agriculture, livestock, public health, construction), and/or commodity fumigation mitigation requirements.

Condition 7: Awardee to support the Mission in the development of any Best Practice Review (BPR) for environmental safeguarding.

Condition 8: Awardee to ensure compliance with partner country environmental regulations, including COVID-19 local and international standards.

Condition 9: Awardee to plan for management of packaging waste associated with commodity distribution and increased waste streams due to communicable diseases.

Condition 10: Awardee to include awareness of pandemic health risks of activities (e.g., irrigation, roads) that disrupt wildlife habitat, and are exacerbated by climate risks in the IEE.

IMPLEMENTATION

In accordance with 22 CFR 216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Sections 3, 4, and 5 of the IEE and any BEO Specified Conditions of Approval. Any significant delinquencies and lack of compliance with 22 CFR 216 will result in a Corrective Action Plan (CAP).6

4 The Supplemental IEE is a subsidiary analysis to the RFA-IEE and may also be referred to as the “Activity IEE”.

5 The ESR is like the Environmental Mitigation and Monitoring Report (EMMR) used elsewhere in USAID. However, the ESR meets purposes of annual reporting and budget planning for environmental compliance.

6 The CAP is mandatory when a project or activity is found to be noncompliant—e.g., failure to comply with IEE conditions, use of pesticides without a PERSUAP, or failure to follow other ADS 204 procedures. The CAP is initiated by USAID and directed to the Process Owner (e.g., AOR/COR, Mission Director, Implementing Partner).

https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/environmental-documentation/cap https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/environmental-documentation/cap

BHA/DRC/RFA IEE 4

USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY NAME: USAID BHA FY23 Request for Applications Initial Environmental Examination (RFA IEE) for Resilience Food Security Activities in DRC

Bureau Tracking ID: BHA FY23 RFA IEE DRC

Clearance:

Jeff Bryan, Director, Office of Africa Date

Diane-Elizabeth Mbanzidi, Mission Environmental Officer (MEO) and Climate Integration Lead (CIL)

Date

David Kinyua, Regional Environmental Advisor Date

Erika J. Clesceri, BHA Climate Integration Lead (CIL) Date

Concurrence:

Erika J. Clesceri, BHA Bureau Environmental Officer (BEO) Date

BHA/DRC/RFA IEE 5

INITIAL ENVIRONMENTAL EXAMINATION

TABLE OF CONTENTS

1.0 PROJECT/ACTIVITY DESCRIPTION 5

1.1 PURPOSE AND SCOPE OF THE IEE 5

1.2 PROJECT/ACTIVITY OVERVIEW 6

1.3 PROJECT/ACTIVITY DESCRIPTION 7

2.0 BASELINE ENVIRONMENTAL INFORMATION 9

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL, THREATENED AND ENDANGERED SPECIES) Error! Bookmark not defined.

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS

(E.G. WHO), ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS Error! Bookmark not defined.

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK 10

3.1 COMMODITY FUMIGATION 10

3.2 COVID-RELATED ACTIVITIES 12

3.3 OTHER BHA PROGRAM AREAS AND ELEMENTS 13

4.0 ENVIRONMENTAL DETERMINATIONS 14

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS 14

4.2 CLIMATE RISK MANAGEMENT 14

4.3 ENVIRONMENTAL THRESHOLD DETERMINATIONS AND CLIMATE RISK RATINGS 14

4.4 CLIMATE RISK MANAGEMENT SUMMARY NARRATIVE 15

5.0 CONDITIONS AND MITIGATION MEASURES 16

5.1 CONDITIONS 16

5.1.1 PRE-AWARD STAGE 18

5.1.2 POST-AWARD STAGE 18

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION 34

7.0 REVISIONS 35

ANNEX A: ENVIRONMENTAL IMPACTS & MITIGATION MEASURES FOR COVID-RELATED ACTIVITIES 36

ANNEX B: PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN (PERSUAP) FOR APPROVED

DISINFECTANTS 42

ANNEX C: CLIMATE RISK MANAGEMENT SUMMARY TABLE 51

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE AND SCOPE OF THE IEE

BHA/DRC/RFA IEE 6

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID intervention described herein and recommend determinations and, as appropriate, conditions, for these activities. Upon approval, these determinations become affirmed, and specified conditions become mandatory obligations of implementation. This IEE also documents the results of the Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

This RFA IEE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound design and implementation. This RFA IEE, cleared by BHA Washington, also establishes the requirements for post-award implementing partners (IPs) to develop their own Supplemental IEEs for Mission clearance and outlines other BEO-specified Conditions for implementation and reporting throughout the life of the awards.

This RFA IEE analyzes the environmental impacts and climate risks related to Commodity Fumigation, and COVID-related activities, given that environmental impacts of and climate risks to these activities are globally consistent. Other activity-types must be analyzed in the partner’s Supplemental IEE to ensure the baseline environmental situation is taken into account.

In 2020, USAID BHA developed Guidance for BHA Resilience Food Security Activity Partners Working in COVID-19 Affected Operating Environments. However, this guideline was not focused on the environmental compliance issues described within this IEE. These include the environmental impacts associated with increased disinfectant and PPE use, as well as risks associated with habitat encroachment and increased communicable disease outbreaks.

1.2 PROJECT/ACTIVITY OVERVIEW

The Bureau of Humanitarian Assistance (BHA), in the U.S. Agency for International Development’s (USAID) is the U.S. Government leader in international food assistance. Through BHA, USAID supports multi-year development (i.e., non-emergency) food security activities to improve and sustain the food and nutrition security of populations who are vulnerable. Development activities are mandated in the Food for Peace Act and are aligned with the USAID 2016-2025 Food Assistance and Food Security Strategy7. These activities work at the individual, household, community and systems level to address the underlying causes of chronic and acute food insecurity and strengthen transformative opportunities. USAID also provides emergency food assistance to address needs arising from natural disasters and complex emergencies, which are often characterized by insecurity and population displacement.

Overall, the Strategic Results Framework Strategic Objectives (SOs) and accompanying Intermediate Results (IRs) address key drivers of food insecurity, creating a map of the broad platform of capabilities that BHA and its partners bring to bear in supporting improved food security for populations in vulnerable conditions. Implementing partners are expected to use innovative approaches to promote environmental risk management to improve and sustain food and nutrition security of populations who are vulnerable, as articulated in both SO1 and SO2 of the USAID 2016-2025 Food Assistance and Food Security Strategy.

7 Please note that BHA will be developing new strategies. See webpage here: https://www.usaid.gov/humanitarian-assistance for updates.

https://www.usaid.gov/environmental-procedures/laws-regulations-policies/22-cfr-216 https://www.usaid.gov/environmental-procedures/laws-regulations-policies/22-cfr-216 https://www.usaid.gov/ads/policy/200/201mal https://www.usaid.gov/sites/default/files/2022-05/External_Guidance_for_DFSA_in_COVID-19_FINAL_508_Compliant.pdf https://www.usaid.gov/sites/default/files/2022-05/External_Guidance_for_DFSA_in_COVID-19_FINAL_508_Compliant.pdf https://pdf.usaid.gov/pdf_docs/pa00mcqp.pdf https://pdf.usaid.gov/pdf_docs/pa00mcqp.pdf https://www.usaid.gov/humanitarian-assistance

BHA/DRC/RFA IEE 7

As specified in the RFA, BHA investments in the target BHA geographies8 will contribute to USAID’s Strategy by strengthening community resilience, protecting and enhancing livelihoods, and improving food and nutritional security of households that are vulnerable.

1.3 PROJECT/ACTIVITY DESCRIPTION

As described in the RFA, BHA resilience food security activities in DRC are intended to improve and sustain the food and nutrition security of populations who are vulnerable by reducing extreme poverty and strengthening resilience in populations vulnerable to acute, chronic hunger, malnutrition, and recurrent shocks, stresses, and crises. These activities work at the individual, household, community, and institutional levels to address the underlying causes of food insecurity and malnutrition and strengthen transformative opportunities. This includes a focus on improving food access and incomes through agriculture and other livelihoods initiatives; enhancing ecosystem services through natural resources management; combating under-nutrition, especially for children under 2 and pregnant and lactating women; and reducing and mitigating disaster impact through early warning and community capacity strengthening and preparedness activities.

This RFA IEE covers three main activity types: commodity fumigation, support for increased use of disinfectants/germicides and PPE in response to communicable disease transmission (including COVID-19), and support for small and medium enterprises (SMEs) responding to COVID-19. These activities are able to be analyzed at this RFA level given the environmental impacts and climate risks associated with them are applicable globally.

COMMODITY MANAGEMENT: FUMIGATION

BHA makes commodity donations to private voluntary organizations (PVOs) and international organizations (IOs), such as the UN’s World Food Program (WFP). The large majority of commodities are purchased from US farmers and shipped abroad from US ports; however, activities can also distribute locally, regionally, internationally procured (LRIP) food commodities as long as the use of LRIP resources clearly supports interventions that sustainably reduce vulnerability to food insecurity.

In order to prevent the spoilage and waste of food commodities procured by resilience food security funds, a range of protective measures are implemented in commodity storage warehouses. One common protective measure to prevent loss of commodity from insect, fungal or mammal infestations is fumigation utilizing phosphine gas and/or the application of contact pesticides to warehouse surfaces.

POPULATION HEALTH-RELATED ACTIVITIES

This RFA IEE also covers two activities that address communicable disease prevention. These guidelines originate from the COVID-19 response regulation but can inform additional population health interventions relating to communicable disease:

Support for increased use of disinfectants/germicides to minimize communicable disease transmission.

In order to prevent spread of viral pathogens, it is expected that BHA partners will be relying on the increased use of germicides (e.g., disinfectants, sanitizers) to clean surfaces. BHA partners will also be

8 Kasai, Kasai Oriental, and Tanganyika provinces in DRC.

BHA/DRC/RFA IEE 8

using or supporting the use of increased Personal Protective Equipment (PPE) to minimize the spread of viruses, including COVID-19.

Increased use of PPE and support for PPE production to minimize communicable disease transmission.

USAID approved the use of program funds to finance the local production of medical-grade and non-medical grade personal protective equipment (PPE), including for small and medium enterprises (SMEs).

PPE production includes (but is not limited to) masks, gowns, face shields, protective eyewear, boot covers, linens, and gloves.

OTHER BHA ACTIVITIES AND SECTORS

The exemplary range of sectors which may be supported within these resilience food security activities are listed below and further described in the FY23 RFA for Resilience Food Security Activities in DRC.

TABLE 1: EXAMPLE ACTIVITIES AND SECTORS

Commodity Fumigation

Other BHA Program Areas or Elements

Civil Society

HIV/AIDS

Maternal and child health

Family planning and reproductive health

Water supply and sanitation

Environment

Climate Change - adaptation

Climate Change - clean energy

Nutrition

Basic education

Social assistance

Agriculture

Private sector productivity

Financial sector

Protection, assistance and solutions

Disaster readiness

BHA/DRC/RFA IEE 9

2.0 BASELINE ENVIRONMENTAL INFORMATION

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL)

Implementing partners are expected to design their programs to address intervention area-specific biophysical, socioeconomic and cultural conditions, as well as the political and institutional context in which the Resilience Food Security Activities will operate. Applicants are expected to draw from existing USAID or other country-level environmental analyses, including USAID climate change vulnerability and adaptation analyses, (which can be found by searching for DRC in the Climatelinks resource library), DRC-specific reports, and Foreign Assistance Act (FAA) 118/119 Biodiversity and Tropical Forestry Assessments.

The following subsections provide a brief overview of the baseline climate and environmental information, for the sub-national areas of DRC in the BHA geographic zones in the Kasai, Kasai Central, and Tanganyika provinces. It is crucial to understand the baseline (the existing environmental situation or condition in the absence of USAID activities) in order to understand and measure the impacts, or change from the baseline, caused by an activity in these regions.

I. Socio-Economic Overview II. Key Geographic Features

A. Geography B. Soil & Forests C. Water Resources

III. Key Ecological Habitats A. Protected Areas B. Wetlands

IV. Threats A. Environmental Threats Overview B. Invasive Species C. Climate Risks

V. Pests and PERSUAPs VI. Other Key Stakeholders https://www.climatelinks.org/ https://www.usaid.gov/humanitarian-assistance/democratic-republic-of-the-congo https://www.usaid.gov/humanitarian-assistance/democratic-republic-of-the-congo https://pdf.usaid.gov/pdf_docs/Pnads946.pdf

BHA/DRC/RFA IEE 10

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

This section includes analysis for three common activities of fumigation, (given that most BHA activities will use commodity fumigation to prevent the loss of food commodities), increased disinfectant/PPE use, and support for COVID-19-related SMEs. As noted above, these activities can be analyzed at this level given the associated environmental impacts and climate risks are well-understood.

The COVID-19 pandemic has brought unprecedented risks to societies globally. USAID is highlighting environmental risks related to increased disinfectant use and waste management to ensure that responses to the pandemic do not introduce additional risks and challenges for communities. Most BHA activities will be impacted by COVID-19 in addition to endemic communicable diseases.

However, the environmental impacts and climate risks of other BHA activities will depend on the specific context in which activities are implemented. Further, BHA activities are typically undefined at the RFA level, which makes the evaluation of potential environmental impacts and climate risks difficult.

Therefore, analyses of the environmental impacts and climate risks of other activities need to be undertaken in the Supplemental IEE.

3.1 COMMODITY FUMIGATION

Environmental Impacts Most BHA activities will carry out the storage and protection of commodities, either as US in-kind food assistance or as locally-procured food commodities. To prevent the loss of food commodities from pest infestations during storage, it is common practice to perform periodic fumigation of warehouses and/or the application of contact pesticides to warehouse surfaces.

As mentioned in the Fumigation Programmatic Environmental Assessment (PEA), impacts of commodity fumigation must be considered, including:

● Use of the fumigant aluminum phosphide, and to a lesser extent magnesium phosphide, can potentially affect the health of applicators and other on-site workers and visitors.

● Use of the fumigant phosphine gas can affect the health of residents near warehouses being fumigated.

● Fumigation residuals could affect water quality, soil, and non-target organisms.

● Poor practices in transport, storage, application, and disposal of fumigants are a concern for human health.

● Improper disposal practices of rodents and birds killed by phosphine gas could affect human health.

● Phosphine may not completely control fungal contamination.

In addition, it is a USAID agency commitment that activities consider the procurement or promotion of pesticides as a last resort within an Integrated Pest Management (IPM) framework (see USAID Special Topic Presentation on Pesticides). Whichever their intended use may be, pesticides are potent killing agents and their use poses intrinsic dangers to applicators, households, communities and the environment. These risks include, but are not limited to:

● Use of chemical, non-organic compound-based, and biological or botanical-based pesticides can potentially affect the health of applicators, on-site workers and visitors.

https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/fumigation-pea https://usaidgems.org/Workshops/Sahel2018Materials/Session17a_Environmental%20Comliance%20for%20Pesticide%20Use-PERSUAP-amn.pdf https://usaidgems.org/Workshops/Sahel2018Materials/Session17a_Environmental%20Comliance%20for%20Pesticide%20Use-PERSUAP-amn.pdf

BHA/DRC/RFA IEE 11

● Poor practices in the transport, storage, application, and disposal of pesticides and pesticide containers are a concern for human and environmental health.

● Pesticides can negatively affect and/or eliminate non-target organisms in the environment, (i.e., predatory insects and pollinators, microorganisms beneficial to soil health, aquatic organisms, etc.) thereby altering ecological food webs and potentially causing detriment to agricultural production systems.

● Chemical pesticides can contaminate surface and groundwater water, soils, and can bioaccumulate in surrounding ecosystems and organisms, posing a concern for health.

● Misuse or overuse of pesticides can result in pesticide-resistance.

Climate Risks As noted in Section 2, DRC will experience increasing temperatures. Climate hazards including heat waves, drought, and heavy precipitation and flooding (potentially leading to landslides and erosion) occur. Based on the most recent information and models, it is clear that the future will increase climate variability and extreme events. The climate changes expected in DRC could impact fumigation by changing herbivore and pathogen range and occurrence, which should also be considered during fumigation, and threatening the effectiveness of fumigation storage effectiveness.

TABLE 2: POTENTIAL ENVIRONMENTAL IMPACTS AND CLIMATE RISKS OF COMMODITY FUMIGATION

Commodity Fumigation

Potential environmental and social impacts Potential climate risks

Warehouse treatment of bagged and bulk commodity

● Negative health impacts to applicators and on-site workers and visitors (including transporters)

● Negative health impacts of residents near fumigation sites

● Negative impacts to water quality, soil and non-target organisms if fumigant disperses from the site

● Negative health impacts due to poor solid waste management (such as improper disposal of dead birds and rodents killed by fumigants) of fumigation residues/byproducts

● Need for ancillary treatment of fungal diseases as Phosphine may not be effective in control of fungal contamination

● Certified applicators unwilling to use personal protective equipment due to increased temperatures.

● Increased temperatures and changes in rainfall patterns, changes occurrence of pests and pathogens and therefore fumigation requirements.

● Warehouses where commodities are stored are in locations threatened by extreme weather, or in flood zones.

BHA/DRC/RFA IEE 12

3.2 POPULATION HEALTH RELATED ACTIVITIES

Environmental Impacts The COVID-19 pandemic and its response activities have had both direct and indirect environmental and health impacts. For example, BHA response activities include increased disinfectant use, which can have negative impacts on human health without oversight, and increased PPE use and production which can lead to waste management challenges. Indirect impacts relate to coping mechanisms for individuals and communities whose livelihoods have been impacted by COVID-19. For example, deforestation rates are spiking in many areas of the world as a result of economic hardship related to COVID-19. The lessons learned from COVID-19 response activities and their subsequent impacts can also inform other communicable disease responses and population health interventions. In recent years, the DRC has experienced outbreaks and/or increases in cases of Ebola virus disease, measles, meningitis, typhoid fever, Mpox and influenza. The increased use of PPE and disinfectants to combat these outbreaks calls for similar waste management interventions as established during COVID-19.

The anticipated environmental impacts of communicable diseases are both direct and indirect.

Communicable disease response actions relate directly to Activity 2 (disinfectant use), and Activity 3 (COVID-19 PPE production for small and microenterprise support (SME) support).

Environmental and human health impacts related to:

● Exposure to COVID-19 and other communicable diseases at gatherings, informational sessions, and during essential work;

● Exposure to disinfectants/germicides, and hazardous wastes (medical waste, pharmaceuticals, electronics) in health facilities, businesses, public spaces, and/or households; and

● Increased exposure to zoonotic diseases through wildlife trafficking.

Direct environmental and ecological impacts related to:

● Pollution/contamination from inappropriate use or management of disinfectants;

● Pollution/contamination from inappropriately managed Small and Medium Enterprises (SMEs), such as those producing PPE or sanitizer;

● Increase in infectious waste stockpiles, as PPE use increases; and

● Increase in the use of single-use plastics, as, in some cases, plastic bag bans are lifted to minimize the spread of the virus on reusable bags.

Indirect environmental and ecological impacts related to:

● Increased deforestation due to reduced policing of international timber exploitation and community member livelihood coping mechanisms (e.g., charcoal making, firewood); and

● Increased non-timber forest products (e.g., wildlife trafficking), and associated minerals exploitations (e.g., artisanal gold, tantalum, tin, bauxite, mining etc.).

Climate Risks Climate and weather shocks and stressors can cause direct and indirect negative impacts to human health, such as heat waves leading to increased heat related illness or changing temperatures and rainfall patterns changing the distribution of infectious diseases. These impacts may magnify the severity of communicable disease outbreaks. Furthermore, climate and weather shocks and stressors may also

BHA/DRC/RFA IEE 13

weaken health systems, and these systems' ability to respond to emerging outbreaks. Populations who are in conditions of acute vulnerability are usually the most impacted by climate and weather shocks and stressors, potentially putting more people at risk of serious illness. An example of the interplay between climate and population health can be found in the seasonality of COVID-19, with higher temperatures acting as a protective factor in reducing COVID-19 spread and colder seasons subject to infection surges.

3.3 OTHER BHA PROGRAM AREAS AND ELEMENTS

This RFA IEE cannot determine the reasonably foreseeable potential environmental impacts and climate risks of interventions within the BHA Activities and Sectors described in Section 1.3, as the scope and technical approach of these interventions have not yet been defined. These interventions will be refined and analyzed in Supplemental IEEs. The following illustrative examples should not be used as a definitive determination or to determine the scope of an action's impact. The DRC Climate Risk Profile can be utilized to inform project scope and potential intervention impacts.

https://drive.google.com/file/d/14lz2HIo8hiK7zzuvSbVRC2MZRaxRwmWc/view

BHA/DRC/RFA IEE 14

4.0 ENVIRONMENTAL DETERMINATIONS

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS

A Positive Determination, pursuant to 22 CFR 216.3(b)(l)(ii), is recommended for all commodity fumigation activities that use a restricted use pesticide, as registered by the USEPA. Please see additional information in Section 5 under Condition 6b.

A mid risk rating of a Negative Determination applies for the COVID-related activities:

● Support for increased use of disinfectants/germicides and PPE in response to COVID-19

● Support for small and medium enterprises (SMEs) responding to COVID-19

A Deferral is recommended for all other activity interventions that are not yet well defined in scope or technical approach pursuant to 22 CFR 216.3(a)(7)(iv). The Deferral for these interventions, must be resolved in the post-award Supplemental IEE, in which each intervention will be assigned a threshold determination: Categorical Exclusion, Negative Determination with Conditions or Positive Determination.

Most activities that previously qualified as a Categorical Exclusion (training, capacity building, meetings, etc.) now present a risk of transmission through workplace exposure, and hence are re-classified as a Negative Determination9. This determination will remain in place until further notice from the BEO, contingent on approved vaccines and testing being widely-available and accessible.

4.2 CLIMATE RISK MANAGEMENT

The recommended climate risk rating for commodity fumigation is based on the anticipated likelihood and severity of climate risk, per 201mal. Low, moderate, and high risk ratings were identified based on likely climate risks to commodity fumigation.

For COVID-19-related activities, support for increased use of disinfectants/germicides to minimize COVID- 19 transmission receives a moderate climate risk rating, while support for increased use of PPE and support for PPE production to minimize COVID-19 transmission receives a low climate risk rating.

For all other BHA activities, the climate risk rating is postponed, to be assessed with the supplemental IEE analysis.

The following table summarizes the recommended determinations and climate risk ratings based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22 CFR 216.

4.3 ENVIRONMENTAL THRESHOLD DETERMINATIONS AND CLIMATE RISK RATINGS

TABLE 3: ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

9 Research activities, virtual meetings, and other activities that do not involve in-person meetings or gatherings still qualify as

Categorical Exclusion.

BHA/DRC/RFA IEE 15

Illustrative Interventions 22 CFR 216 Environmental Determination Climate Risk Rating

Commodity Fumigation Positive Determination Low, moderate, and high (see CRM table)

Support for increased use of disinfectants/germicides to minimize COVID-19 transmission10

Negative Determination with Conditions Moderate

Support for increased use of PPE and support for PPE production to minimize COVID-19

Negative Determination with Conditions Low

Agriculture Deferral for all other BHA Activities, to be assessed in the Supplemental IEE.

Postponed Assessment, Rating to be assessed along with Supplemental IEE analysis

Other BHA Activities Deferral for all other BHA Activities, to be assessed in the Supplemental IEE.

Most activities that typically qualify as a Categorical Exclusion (training, capacity building, meetings, etc.) will no longer apply. Activities that would previously qualify for a low or no risk, or a Categorical Exclusion, but now present a risk of COVID-19 transmission through workplace exposure, must qualify as Negative

Determination with Conditions.

Postponed Assessment, Rating to be assessed along with Supplemental IEE analysis

4.4 CLIMATE RISK MANAGEMENT SUMMARY NARRATIVE

This climate risk management screening is conducted at the global level for BHA as part of the pre-award CRM process. The intention is to capture the climate risks that could affect activities anticipated under BHA awards. Given that the specific geographies (e.g., country, region, and coastal proximity), climate conditions, adaptive capacity, and other key characteristics that can shape risk are not yet defined at this level of analysis, the screening focuses on risks that can be broadly applied for a specific type of activity --in this case, fumigation. Post-award, the partner will complete full screening once activity and geography details are defined. CRM must be provided for all activities, regardless of activity type. A critical resource used in identifying and assessing the climate risks was USAID’s Climate Risk Screening and Management Tool for Strategy Design + Annexes.

10 As new COVID-19 safety protocols are established globally and implemented (e.g., social distancing, virus and antibody testing, contact tracing, etc.), this determination may be subject to change.

https://www.climatelinks.org/resources/climate-risk-screening-management-tool https://www.climatelinks.org/resources/climate-risk-screening-management-tool https://www.climatelinks.org/resources/climate-risk-screening-management-tool

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5.0 CONDITIONS AND MITIGATION MEASURES

5.1 CONDITIONS

For applicants, USAID BHA environmental compliance at the time of activity design will be met through adherence to both 1) this RFA IEE and 2) completion of a stand-alone, Supplemental IEE, only upon USAID’s indication of an intent to award. Once the Supplemental IEE, including the Environmental Mitigation and Monitoring Plan (EMMP), CRM screening, and IAP (including attendant budget), is finalized and approved by the BHA, the IEE is to be used to guide activity implementation. All mitigation measures contained in the Supplemental IEE must be implemented and monitored for effectiveness in reducing potential environmental impacts resulting from interventions.

The following 10 conditions (explained in more detail in the sections that follow) describe awardees’ environmental compliance, mitigation, monitoring and evaluation responsibilities throughout the life of award (LOA). Figure 2 below provides a visual schematic of the requirements over LOA.

● Condition 1: Applicant to submit Environmental Safeguards Plan.

● Condition 2: Awardee to develop Supplemental IEE for Mission and Washington clearance by the end of the R&I Year.11

● Condition 3: Implement environmental monitoring requirements. This includes development and alignment of Environmental Mitigation and Monitoring Plan (EMMP) and Climate Risk Management (CRM) with performance M&E systems.

● Condition 4: Awardee to submit Environmental Status Reports (ESRs) annually before the Pipeline Resource Estimate Proposal (PREP). Additional reporting is reflected in the Annual Results Report

(ARR).

● Condition 5: Develop an Environmental Assessment for any actions with potential for significant impact to ecological habitats, as determined by USAID.

● Condition 6: Plan for a Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP), which includes for pesticide procurement and/or use (e.g., agriculture, livestock, public health, construction), and/or commodity fumigation mitigation requirements.

● Condition 7: Support the Mission in the development of any Best Practice Review (BPR) for environmental safeguarding.

● Condition 8: Ensure compliance with partner country environmental regulations, including COVID- 19 local and international standards.

● Condition 9: Plan for management of packaging waste associated with commodity distribution and increased waste streams due to communicable diseases.

● Condition 10: Include awareness of pandemic health risks of activities (e.g., irrigation, roads) that disrupt wildlife habitat, and are exacerbated by climate risks in the IEE.

11 The Supplemental IEE is subsidiary analysis to the RFA-IEE and may also be referred to as the “Activity IEE”.

Document Submission: Abacus

Please note that as soon as Abacus functionality allows, all RFSA Environmental Compliance documentation will be submitted through the Abacus system.

BHA/DRC/RFA IEE 17

The environmental determinations in this IEE are contingent upon these general implementation and monitoring requirements, as well as ADS 204 and other relevant requirements.

Figure 2: Overarching Environmental Compliance Flowchart for BHA Activities https://www.usaid.gov/ads/policy/200/204 https://www.usaid.gov/ads/policy/200/204

BHA/DRC/RFA IEE 18

5.1.1 PRE-AWARD STAGE

CONDITION 1: APPLICANT TO SUBMIT ENVIRONMENTAL SAFEGUARDS PLAN

USAID requires analyses which consider environmental risks across the Agency, using a set of defined procedures to meet USAID environmental requirements. Applicants are expected to design innovative approaches to promote environmental and climate risk management to improve and sustain food and nutrition security of populations who are vulnerable, as articulated in both SO1 and SO2 of the USAID 2016-2025 Food Assistance and Food Security Strategy. Applicants must summarize these environmental approaches into a four-page Environmental Safeguards Plan.

This plan must summarize:

1. How strategies to reduce both environmental impacts of the activity and climate risks to the activity have been integrated into activity design, including management of packaging waste from commodity distribution12;

2. How funds for environmental and climate risk management have been allocated in the detailed/comprehensive budgets and described in the budget narrative;

3. How staffing for oversight of environmental compliance requirements will be carried out over the life of the activity; and

4. How outcomes of the EMMP will inform performance as monitored through the Logical Framework and Indicator Performance Tracking Tables (IPTT) in M&E systems.

5.1.2 POST-AWARD STAGE

CONDITION 2: AWARDEE TO DEVELOP SUPPLEMENTAL IEE FOR MISSION AND WASHINGTON

CLEARANCE BY THE END OF THE R&I YEAR

IEE Development

Upon receipt of the BHA award, implementing partners will be required to develop a Supplemental IEE13, specific to the award. The Supplemental IEE will describe the environmental impact analysis for all interventions in the project’s zone of influence, within the BHA geographies described in the RFA. In short, the Supplemental IEE must 1) summarize the technical design, 2) describe baseline environmental conditions in the BHA zones of influence 3) identify all reasonably foreseeable environmental impacts of interventions, and 4) recommend sound mitigation measures to prevent, reduce or compensate for environmental impacts. Partners should integrate local knowledge to identify environmental impacts and recommend mitigation measures as part of the environmental impact assessment process.

Partners must provide sufficient site-specific information in the S-IEE in order to understand the specific baseline environmental conditions. The inclusion of maps, photos, and geographic coordinates is highly recommended. Further, partners must consider the cumulative impacts of activities occurring in their zones of influence, which can ultimately rise to a Positive Determination, requiring an Environmental Assessment. For example, cumulative impacts could include over-withdrawal of water for irrigation

12 See Condition 9A for more information on packaging waste 13 A word version of the Supplemental IEE template can be found at a Google drive here:

https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8 https://www.usaid.gov/FFPStrategy https://www.usaid.gov/FFPStrategy

BHA/DRC/RFA IEE 19

and/or water point provision or increases in pollutant concentrations in a water body or in the soil or sediments.

In order for IEEs to include sufficient level of detail to describe to USAID the potential level of environmental risk, the IEE must include sufficient information about the scope, scale, and locations of anticipated activities. As always, if the partner does not have sufficient information to inform environmental and climate risk analysis at this stage, then the PVO must request Deferral, per 22 CFR 216.3.(1)(iii).

COVID-19 IEE Implications

As noted above in Section 4.3, most activities that previously qualified as a Categorical Exclusion (training, capacity building, meetings, etc.) now present a risk of transmission through workplace exposure, and hence are re-classified as a Negative Determination. This determination will remain in place until further notice from the BEO, contingent on approved vaccines and testing being widely-available and accessible. Research activities, virtual meetings, and other activities that do not involve in-person meetings or gatherings still qualify as Categorical Exclusion. Despite receiving a Negative Determination, activities that previously qualified as a Categorical Exclusion but now present a risk of transmission can still proceed in the Refinement Year prior to IEE submission and approval.

IEE Timing

Partners must submit their S-IEEs towards the end of the refinement year (Year 1) when activities are better defined so IEEs contain sufficient details about the scope and scale of activities. For any adjustments to this timing the AORs must work with the BEO to determine what timing makes sense.

https://www.usaid.gov/our_work/environment/compliance/22cfr216 https://www.usaid.gov/our_work/environment/compliance/22cfr216

BHA/DRC/RFA IEE 20

Box 1: Low-Risk Activities Allowed to Proceed in Refinement Year Prior to Supplemental IEE

Partners can proceed with low-risk activities that typically qualify as “Categorical Exclusion” during the refinement year prior to IEE submission and approval.

However, activities with moderate or unknown risks (“Negative Determination with Conditions”) must have an IEE in place before implementation. This includes any activities involving interventions of physical nature, or activities that involve pesticide procurement, use, or support, which trigger USAID pesticide procedures per 22 CFR 216.3(b). See Condition 6 below for more information on pesticides.

If a S-IEE must be developed during the refinement year for activities with a “Negative Determination”, all other activities, where scope and scale are still undefined, can receive a “Deferral” to be analyzed at a later point in an IEE-Amendment.

Per the RFA, Section C, Activity Design, activities commonly implemented during the refinement year include, but are not limited to the following six (6) activities:

Low-risk activities:

1. Re-implementation formative research and analysis that addresses evidence and knowledge gaps, and strengthens understanding of local context, and helps to prioritize behaviors the activity will address;

2. Meaningful community engagement to 1) enable two-way feedback and participation around the planned activity, interventions and refinement period, 2) enhance understanding of local needs, opportunities and aspirations, and 3) ensure mutual accountability, including in decision making processes.14

3. Participatory stakeholder engagement for strengthened local partnerships, capacity strengthening and coordination;

4. Refining the TOC and implementation plans; and

5. Preparation for implementation through hiring, staff training, and procurement of goods and services.

Potential moderate or unknown risk activities:

6. Small-scale operational research, piloting implementation strategies, and start-up of proven, evidence-based implementation strategies;

IEE Amendments

In the event that any new proposed interventions differ substantially from the type and/or agro ecological zone of interventions described in the Supplemental IEE, an IEE Amendment (IEE-A) will be developed, including a revised EMMP (and potentially revised IAP and CRM screening, as needed).

Amendments must be sent to BHA and reviewed for approval by the BHA/BEO prior to implementation.

Some of the possible triggers for an IEE-A include, but are not limited to: modified or new interventions;

new geographic zone; cost extension; and/or significant time extension, such as an additional year.

14 Community briefings and consultative processes should take place in every community, while more extensive community visioning sessions should be carried out in a robust subset of communities.

BHA/DRC/RFA IEE 21

Pursuant to 22 CFR 216.2(b), activities involving international disaster assistance or other emergency circumstances may be Exempt from these procedures. Emergency activities with Agreement Officer approval may be Exempt from environmental review, such as the transfer of food commodities pursuant to 22 CFR 211.

It is important to note, EMMP modifications do not require an IEE amendment or USAID approval.

However, all EMMP changes and their rationale, should be reported in subsequent ESRs. EMMP revisions during the course of implementation, such as fine-tuning mitigation measures or including additional analysis for unexpected impacts, are encouraged as part of any activity’s sound adaptive environmental management.

While BHA Operating Units do not anticipate implementing COVID-19 response activities outside the scope of existing Results Frameworks, USAID recognizes that the COVID-19 situation is evolving and projects will have to respond accordingly. A/CORs must monitor the implementation of COVID-19 response activities for any actions outside of the existing scope assessed by office-specific IEEs. A/CORs must report these actions to the MEO and BEO for resolution on a case-by-case basis.

Sharing Relevant Documentation. Partners are encouraged to share with the BEO (via AORs) any documents developed during the pre-award and R&I period that could support the BEO’s review and understanding of the environmental and climate risks associated with anticipated project activities (i.e., gender analyses, feasibility studies, etc.). Documentation sharing will help avoid undue burden and duplication of information by partners throughout the environmental compliance documentation review and clearance process.

Resources. There are important resources that partners can consult when developing Supplemental IEEs:

● For guidance on Environmental Impact Assessment (EIA), consult USAID’s EIA Tool.

● For a general introduction on how to develop an IEE, consult the USAID IEE Assistant.15

● Partners are advised to consult previous Supplemental IEEs to research common environmental concerns and solutions among BHA activities globally. Partners can utilize the USAID Environmental Compliance Database to search for USAID-approved IEEs.

● For technical guidance on environmentally sound design and management for USAID development activities, consult the USAID Sector Environmental Guidelines.

● For guidance on stakeholder engagement, consult the USAID Environmental Compliance Factsheet on Stakeholder Engagement.

EMMP Development

As a component of the Supplemental IEE, BHA applicants must complete an EMMP which serves as the implementation and monitoring plan for all required 22 CFR 216 compliance actions to be taken by a given activity. This RFA IEE provides a template for the EMMP in the annexes. Detailed guidance and best-practice considerations for the development of the EMMP is available on the USAID Environmental Procedures Website. The effectiveness of the individual compliance mitigation measures to prevent or reduce environmental impacts must be monitored periodically throughout the life of the activity. The results of this monitoring should be described in the annual ESR. See information below.

15 Provides useful overall process information, but templates are out of date and should not be used.

https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/environmental-documentation/eia https://usaidgems.org/Assistant/ieeAssistant.htm https://ecd.usaid.gov/ https://ecd.usaid.gov/ https://ecd.usaid.gov/ https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/sector-environmental-guidelines-resources https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/sector-environmental-guidelines-resources https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/social-impact-assessment/pdf https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/social-impact-assessment/pdf https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/mitigation-monitoring-reporting https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/mitigation-monitoring-reporting…