J.13 Approved IEE.pdf

AFR/LIBERIA/WASH

USAID LIBERIA WASH

INITIAL ENVIRONMENTAL

EXAMINATION

PROJECT/ACTIVITY DATA

Project/Activity Name: The USAID WASH Project

(a) Improved Access to Safe Water and

(b) Comprehensive County wide Sanitation

Geographic Location(s) (Country/Region): Liberia / West Africa Amendment (Yes/No) Implementation Start/End Date: FY2022 - FY 2026 If Amended, specify New End Date: n/a Solicitation/Contract/Award Number: TBD Implementing Partner(s): TBD Bureau Tracking ID: Liberia WASH IEE https://ecd.usaid.gov/document.php?doc_id=53372 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/Liberia

Other Affected Operating Unit(s): USAID/Liberia Lead BEO Bureau: Africa Bureau Funding Account(s) (if available): Water Directive Original Funding Amount: $ 45MILLION If Amended, specify funding amount: n/a If Amended, specify new funding total: n/a Prepared by: Health and Economic Growth Office, USAID/Liberia Date Prepared: May 29, 2021

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: ☒Environmental Examination

☐Deferral

Environmental Determination(s): ☐Categorical Exclusion(s) ☒Negative Determination with Condition ☐Positive Determination https://ecd.usaid.gov/document.php?doc_id=53372

USAID LIBERIA WASH

☐Deferred (per 22 CFR 216.3(a)(7)(iv) IEE Expiration Date (if different from implementation end date):

December 31, 2027

Additional Analyses/Reporting Required:

Climate Risks Identified (#): Low ______Moderate _X_____ High ______ Climate Risks Addressed (#): Low ___ Moderate __X____ High ______

USAID LIBERIA WASH

THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS

PROJECT/ACTIVITY SUMMARY

The Health Office has designed two new programs under the WASH portfolio; (a) Improved Access to Safe Drinking Water and (b) County Sanitation.

A. The project goal for improved access to safe drinking water is to improve sustainable access to safe drinking water for at least 100,000 people living in the Montserrado and Margibi counties. To achieve this, a multipronged approach will be adopted whereby community engagement, targeted infrastructure upgrades, technical assistance and financial support will be provided.

B. The County Sanitation activity will implement a comprehensive county-wide approach to eliminating open defecation that includes increasing access to basic sanitation services, focusing on improved sanitation governance, adoption of improved sanitation behaviors, strengthened sanitation markets, and increased local financing for sanitation.

TABLE 1: DEFINED OR ILLUSTRATIVE PROJECTS/ACTIVITIES AND SUB-ACTIVITIES

1. Rapid Site Assessments and Consultations

2. Construction and rehabilitation of new water supply structures

3. Technical Assistance and capacity building

4. Community engagement

5. Good governance and financial management of water sector in two counties

6. Latrine construction

ENVIRONMENTAL DETERMINATIONS

The purpose of this IEE, in accordance with 22CFR216, is to provide the first review of the reasonably foreseeable effects on the environment, as well as to provide determinations for this contract. Based on the activities descriptions enumeration, this IEE, in accordance with Title 22, Code of Federal Regulations, Part 216 (22CFR216), 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, per 22CFR216 and specified conditions become mandatory obligations of implementation. This IEE also documents the results of the project/activity level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

This IEE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation. Potential environmental impacts should be addressed through formal environmental mitigation and monitoring plans (EMMPs) and/or Environmental Assessments (EAs), if needed.

The activity will not result in direct environmental impacts. However, the services provided have the potential to cause direct impacts. Therefore, the Contractors providing services and support to USAID will also include environmental safeguards oversight.

USAID LIBERIA WASH

The contractors will ensure that constructed infrastructures are designed and constructed in a manner that:

● Avoids adverse environmental and social impacts wherever possible.

● Restores work sites to acceptable standards; and

● Abides by any environmental performance requirements governed by local laws.

Environmental safeguards oversight shall include, but not be limited to, considerations for the following:

● Minimizing the effect of dust on the surrounding environment resulting from earth moving equipment, vibrating equipment, temporary/permanent access roads, etc. to ensure safety, health and the protection of workers and communities living in the vicinity dust producing activities.

● Ensuring that noise levels emanating from machinery, vehicles, and noisy construction activities (e.g. excavation, blasting) are kept at a minimum for the safety, health and protection of workers within the vicinity of high noise levels and nearby communities.

● Ensuring that existing water flow regimes in rivers, streams and other natural or irrigation channels is maintained and/or re-established where they are disrupted due to works being carried out.

● Preventing oils, lubricants and wastewater used or produced during the execution of works from entering rivers, streams, irrigation channels and other natural water bodies/reservoirs, and ensuring that stagnant water in uncovered borrow pits is treated in the best way to avoid creating possible breeding grounds for mosquitoes.

● Preventing and minimizing the impacts of quarrying, earth borrowing, piling, and building of temporary construction camps and access roads on the biophysical environment including protected areas and arable lands, local communities, and their settlements. In as much as possible restore/rehabilitate all sites to acceptable standards.

● Discouraging construction workers from engaging in the exploitation of natural resources such as hunting, fishing, and collection of forest products or any other activity that might have a negative impact on the social and economic welfare of the local communities.

● Implementing soil erosion control measures to avoid surface runoff and prevents siltation, etc.

● Ensuring that, as much as possible, local materials are used to avoid importation of foreign material and long-distance transportation.

● Ensuring public and worker safety and meeting traffic safety requirements for the operation of work to avoid accidents.

Upon approval of this document, the determinations become affirmed, per Agency regulations (22CFR216). Drawn from Table 4 of the IEE, the following table summarizes the environmental determinations applicable to the specific projects/activities:

TABLE 1: ENVIRONMENTAL DETERMINATIONS

USAID LIBERIA WASH

Projects/Activities Categorical Exclusion Citation

Negative Determination

Positive Determination

Deferral1

Improvement in the governance and financial management of the water service delivery

X

Community engagement and development of service provider accountability framework x

Construction and rehabilitation of new water service delivery structures

X

Technical assistance and capacity building of the water operators

X

Improved national and county level sanitation governance by strengthening ODF policy and regulations

X

Strengthened of sector coordination mechanism and homronization of monitoring

X

Behaviour change of citizens towards sanitation

X

Latrine construction capacity increased

X

CLIMATE RISK MANAGEMENT

Liberia is vulnerable to the impacts of climate variability and change, such as warmer temperatures, increases in annual rainfall, and increases in the frequency of heavy rainfall events.

These climate change impacts present challenges to the country’s socio-economic development.

Liberia’s low adaptive capacity to respond to climate change is partially due to the detrimental effects of the 1989-2003 Civil War. Since the war, the government, along with various international and national institutions and organizations, has been taking actions to better understand and address climate change challenges throughout the country. Remaining needs include data on short and long-term climate change impacts and vulnerabilities within the country, as well as the financial, technological, and human resources to identify adaptation priorities and implement appropriate adaptation plans and strategies.

1 Deferrals must be cleared through an Amendment to this IEE prior to implementation of any deferred activities. USAID/IPs may utilize the Environmental Screening Tool to assess impacts of deferred activities.

USAID LIBERIA WASH

Short-term climate variability is already affecting Liberia, including temperature increases and rainfall variability. As the GoL notes in their new national climate policy, “the impacts of climate change in Liberia not only undermine development gains but also pose serious risk to food security and adaptive capacity,” requiring urgent and concerted national action. As impacts become more pronounced, climate change may erode the progress that Liberia has made and limit gains in the future, including the government’s ability to address its development challenges.

The Climate Risk management results indicated that increased temperatures, changes in amount and duration of rainfall and sea level rise would be addressed through a range of integrated strategies. Engineering analysis preceding design activities will include consideration of climate change and its potential impacts on the location (siting), functionality and sustainability of resulting infrastructure and infrastructure services. Such analysis will include identification of relevant data sets and gaps, review of local building standards and codes for adequacy; and determination of safety factors or other measures of uncertainty that will be carried through design. The results of this analysis, including risks identified and how they are addressed, shall be documented.

BEO SPECIFIED CONDITIONS OF APPROVAL

Reporting Conditions: The AFR BEO requests that the activity managers/AORs/CORs provide access to the Regional Environmental Advisor (REA) and to the AFR BEO Team to review (not approve) the Environmental Mitigation and Monitoring Plans/Reports (EMMPs/EMMRs) that will be written to implement the findings of this IEE. These should be uploaded into the appropriate sub-folder(s) of this Google Drive folder: https://drive.google.com/drive/folders/1q7HGMzgopJ- MuKxkQEJ4GSPp9R7Qzv-5?usp=sharing

This will facilitate access by all parties who need these documents, including the Mission Environmental Officer and the AOR/COR. This will allow the REA and the BEO Team to spot-check and review these documents to confirm that the mitigations seem appropriate and are cognizant of the specific design of the activities.

AFR BEO COVID-19 Conditions:

In order to reduce COVID-19 transmission during the implementation of these activities, USAID managers must:

● Ensure all activities addressed by this IEE adhere to current, applicable COVID-19 guidelines. Refer to the AFR COVID-19 PIEE (attached and linked here --https://ecd.usaid.gov/document.php?doc_id=52754) for links to U.S. and international guidance on appropriate measures to reduce COVID-19 transmission. Such measures may include, but are not limited to social distancing, use of personal protective equipment, limiting the size of gatherings and travel, and effective disinfection.

● Share with the partner:

Applicable COVID-19 guidance from the USAID Mission or U.S. Embassy;

Applicable COVID-19 guidance from local authorities;

https://drive.google.com/drive/folders/1q7HGMzgopJ-MuKxkQEJ4GSPp9R7Qzv-5?usp=sharing https://drive.google.com/drive/folders/1q7HGMzgopJ-MuKxkQEJ4GSPp9R7Qzv-5?usp=sharing https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fecd.usaid.gov%2Fdocument.php%3Fdoc_id%3D52754&data=04%7C01%7CJaime.Capron%40cadmusgroup.com%7Cc108826ce00840cc9b5908d8b8c2d747%7C9775d500e49b49a79e241ada087be6ee%7C0%7C0%7C637462494425770023%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=VZLUskuakAGvLJx7aLUjqx0oh3ncBLsA97DMi8FKow0%3D&reserved=0

USAID LIBERIA WASH

The following Agency-wide “COVID-19 GUIDANCE FOR IMPLEMENTING PARTNERS” page on the USAID website: https://www.usaid.gov/work-usaid/resources-for-partners/covid-19-guidance-implementing-partners.

Ensure that partners have appropriate training, authorization, and resources to meet the expectations of the applicable guidance while implementing these activities.

WQAP Conditions

As there are WASH activities covered under this IEE, the AFR BEO requires that a water quality assurance plan (WQAP) is prepared according to the WQAP Template (https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/special-compliance-topics/water):

Complete a WQAP for WASH-related activities under this IEE, and request and receive AFR BEO review and approval of WQAP.

Clearly link the WQAP to this IEE.

The review results should be written and on record in the Signing Statement of the WQAP.

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 Sections 3, 4, and 5 of the IEE and any BEO Specified Conditions of Approval. Per 22CFR216.3(a)(9), when ongoing programs are revised to incorporate a change in scope or nature, a determination will be made as to whether such change may have an environmental impact not previously assessed. If so, this IEE will be amended to cover the changes. Per ADS 204, it is the responsibility of the USAID AOR/COR to keep the MEO/REA and BEO informed of any new information or changes in the activity that might require revision of this environmental analysis and environmental determination.

https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.usaid.gov%2Fwork-usaid%2Fresources-for-partners%2Fcovid-19-guidance-implementing-partners&data=04%7C01%7CJaime.Capron%40cadmusgroup.com%7Cc108826ce00840cc9b5908d8b8c2d747%7C9775d500e49b49a79e241ada087be6ee%7C0%7C0%7C637462494425770023%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=iaSs47VZuKVKNsxvUcsvi1iJCVJdcXfmxweQFrUhf5U%3D&reserved=0 https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.usaid.gov%2Fwork-usaid%2Fresources-for-partners%2Fcovid-19-guidance-implementing-partners&data=04%7C01%7CJaime.Capron%40cadmusgroup.com%7Cc108826ce00840cc9b5908d8b8c2d747%7C9775d500e49b49a79e241ada087be6ee%7C0%7C0%7C637462494425770023%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=iaSs47VZuKVKNsxvUcsvi1iJCVJdcXfmxweQFrUhf5U%3D&reserved=0 https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/special-compliance-topics/water https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/special-compliance-topics/water

USAID LIBERIA WASH

USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY NAME: Improved Access to Safe Water and County Sanitation

Bureau Tracking ID: https://ecd.usaid.gov/document.php?doc_id=53372

Approval: Cleared 05/16/2021 Sara L. Walters, Mission Director Date

Clearance: Cleared 04/06/2021 Zulfikar Gorar, WASH Systems Advisor / Design Team Lead Date

Clearance: Cleared 04/06/2021 Jessica Healey, Director Health Office Date

Clearance: Cleared 04/15/2021 John Pasch, Director Economic Growth Office Date

Clearance: Cleared 04/17/2021 Kokulo Y. Yorgbor Jr., Mission Environmental Officer Date

Clearance: Cleared 04/28/2021 Kimberlee Bell, Director, Program/Planning Office Date

Clearance: Cleared 05/05/2021 Henry Aryeetey, Regional Environmental Officer Date

Clearance: Cleared 04/30/2021 Ronald “Ro” Wietecha, Regional Legal Advisor Date

Clearance: Cleared 05/05/2021 Rebekah Eubanks, Deputy Mission Director Date

Clearance: Cleared 06/14/2021 Colin Quinn, Bureau Climate Integrated Lead Date

Concurrence: 06/14/2021 Brian Hirsch, AFR Bureau Environmental Officer Date

DISTRIBUTION:

https://ecd.usaid.gov/document.php?doc_id=53372

USAID LIBERIA WASH

INITIAL ENVIRONMENTAL EXAMINATION

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE AND SCOPE OF IEE

The purpose of this initial environmental examination is to have an environmental document in place to guide the contractor, and in fulfillment of its legal obligation.

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22CFR216), 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, per 22CFR216 and specified conditions become mandatory obligations of implementation. This IEE also documents the results of the project/activity level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

This IEE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation. Potential environmental impacts should be addressed through formal environmental mitigation and monitoring plans (EMMPs) and/or Environmental Assessments (EAs), if needed.

1.2 PROJECT/ACTIVITY OVERVIEW

1.2.1: Improved Access to Safe Drinking Water

The overall goal of the project is to successfully eliminate the use of unimproved / surface water in the peri urban areas of Montserrado and Margibi counties. This objective will be achieved by adopting a multi-pronged approach such as;

1. Improvement in the governance and financial management of the water service delivery

2. Community engagement and development of service provider accountability framework

3. Construction and rehabilitation of new water service delivery structures

4. Technical assistance and capacity building of the water operators

1.2.2 PROJECT/ACTIVITY DESCRIPTION

The overall goal of the activity is to eliminate the use of surface water in the peri urban areas of Montserrado and Margibi counties and help at least 100,000 people gain access to achieve at least a basic level of sustained service, thus breaking the vicious cycle of infant mortality and disease and creating a healthy workforce for the country. Specific objectives of the project are;

USAID LIBERIA WASH

1. Rapid assessment and mapping of communities according to availability of drinking water services and management of services in the peri urban areas2 of Montserrado and Margibi counties.

2. Consult the local communities especially women organizations, county administration, line department of central government entities, national and international NGOs to propose / develop sustainable, context specific solutions with low operations and maintenance cost to water service delivery in selected areas of the two counties. As an an illustrative example, the solutions can be (a) decentralized piped scheme connected to new or rehabilitated bore hole source, (b) water kiosks connected to an over head water tower

3. Provision of technical assistance and capacity building at the level of (a) community, (b) water service operator, (c) county administration to achieve following results

a. Enable community groups to hold water service providers accountable for services.

b. Capacity building for the county to lead the coordination and monitoring of the water service delivery in counties.

c. Technical assistance and capacity building for the water service provider to plan, budget and mobilize resources for a sustainable and continued water service delivery.

4. Strengthening of the governance and institutional mechanism for water service delivery in two counties by

a. Framing rules of business for counties to adopt the Decentralization ACT of 2017 for improvement of water and sanitation services.

b. Technical assistance to the National WASH Commission for monitoring and regulating the water service delivery and financial performance of water operators in two counties.

c. Establish a system of water levy for water operator, which can be retained by the operator

d. Create an enabling environment and propose cross-subsidies for groups of people who cannot afford water services.

1.2.3: COUNTY SANITATION

The County Sanitation activity will implement a comprehensive county-wide approach to eliminating open defecation that includes increasing access to basic sanitation services, focusing on improved sanitation governance, adoption of improved sanitation behaviors, strengthened sanitation markets, and increased local financing for sanitation. The project will undertake following activities;

1. Improved national and county level sanitation governance by strengthening ODF policy and regulations

2 Peri-urban areas are physically just outside existing urban areas and have characteristics of urban conditions: dense populations, specific economic activities, and an intensive concentration of mobility, with the population living there usually utilizing services in the city.

USAID LIBERIA WASH

2. Strengthened of sector coordination mechanism and harmonization of monitoring

3. Behavior change of citizens towards sanitation

4. Latrine construction capacity increased

5. Increase in number of functional latrines.

TABLE 2: DEFINED OR ILLUSTRATIVE PROJECTS/ACTIVITIES AND SUB-ACTIVITIES

1. Rapid Site Assessments and Consultations

2. Construction and rehabilitation of new water supply structures

• Develop water sources (e.g., borehole, surface water from river or spring), transmit water to a holding tank and treat water. A distribution structure - built under this project – will dispense the water.

• The water would be treated chemically using NaHClO3 (proportional to the quantity). The treatment will be gauged and monitored.

• The power supply to the system will be mostly electric through solar power.

• The locations for the water systems are Rural Montserrado and Margibi County.

3. Technical Assistance and capacity building

4. Community engagement

5. Good governance and financial management of water sector in two counties

6. Latrine construction

• This sanitation project will strengthen markets to finance building of latrines connected to septic tanks.

• The locations are Lofa, Nimba, Bong, Montserrado and Grand Bassa.

USAID LIBERIA WASH

2.0 BASELINE ENVIRONMENTAL INFORMATION

Liberia has four major ecological zones: coastal plains; upper highland tropical forest; lower tropical forest zone; and a northern savannah zone and lies entirely within the Upper Guinean Forest ecosystem. Liberia contains two of the last three remaining large blocks of Upper Guinean Rainforest in West Africa. These biologically rich forests are home to approximately 240 timber species, 2,000 flowering plants, 600 bird species, 125 mammal species, 74 species of reptile, and more than 1,000 insect species.3 The Upper Guinean Forest ecosystem and is identified by Conservation International as a “Biodiversity Hotspot.”

The Environmental Threats and Opportunities Assessment (ETOA) completed by USAID/Liberia in late 2018 identified several concerns related to development, natural resource management, the lack of water and waste management infrastructure, and the lack of enforcement of environmental laws. As a result of the destruction of Liberia ‘s infrastructure during the prolonged conflict, piped water, drainage, wastewater, and solid waste management systems are severely lacking. As the ETOA points out, in spite of the EPA Act and the EPM Law that authorize the creation of regulations, rules, standards and guidelines, as well as the provide for penalties for violation, EPA has not officially promulgated any of these regulations, rules, standards and guidelines, so enforcement is not possible. The absence of a law enforcement division within the FDA also appears to hamper enforcement efforts.

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL,

CLIMATE, SOCIAL)

USAID/Liberia has been supporting various infrastructure projects (building construction including clinics, schools, and government buildings; roads; WASH infrastructure including water treatment facilities and water distribution systems; energy infrastructure including electrical distribution networks and solar systems) in Liberia. USAID/Liberia makes direct and/or indirect infrastructure investments in schools, hospitals, public/community buildings, roads and/or culverts/bridges, and public water supply and sanitation systems. The Mission’s infrastructure projects are an important component of our development programs. To improve both timely and cost-effective construction services, the Mission intends to utilize local construction firms to construct various infrastructural activities.

Through this contract, the construction firms will expand the water network in Peri Urban communities Montserrado and Margibi Counties. This Peri Urban Water construction services is in line with the mission’s overall development objectives in the Economic Growth, Health, Education, Democracy and Governance Offices.

One or more of the following construction services will be required under this contract:

a. Water Distribution Headers and Networks and

b. Transportation to include, culverts and drainage structures.

3 UNDP (in collaboration with EPA of Liberia), State of the Environment Report for Liberia 2006 (2006).

USAID LIBERIA WASH

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL

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

REGULATIONS

THE ENVIRONMENTAL PROTECTION AGENCY ACT OF 2003 (EPA ACT)

The Environmental Protection Agency Act of (EPA Act) authorized the establishment of an overall institutional framework for sustainable management of the environment in Liberia.

NATIONAL ENVIRONMENTAL POLICY COUNCIL

The National Environmental Policy Council is responsible for formulating national environmental policy; setting environmental protection priorities, goals, and objectives; and promoting inter-sectoral, private-public cooperation in the achievement of environmental policy.

LINE MINISTRY ENVIRONMENTAL UNITS

To facilitate the coordination between the EPA and Line Ministries, the EPA Act requires each Line Ministry to establish an environmental unit. The units are charged with ensuring compliance with the requirements of the act, making comments on environmental impact assessments, and liaising with the EPA on environmental management.

ENVIRONMENTAL PROTECTION AND MANAGEMENT LAW

The Environmental Protection and Management Law (EPML) forms the legal framework for the sustainable development, management, and protection of the environment by the Environmental Protection Agency in partnership with relevant ministries, autonomous agencies and organizations.

Liberia’s Environmental Protection Agency (EPA) 4 In keeping with Agency policies for provision of government to government assistance, USAID is committed to designing and implementing programs jointly with the partner government, and to implementing the programs using the partner government policies and procedures to the extent possible. The EPA Act establishes EPA as “the principal authority in Liberia for the management of the environment.” The EPA is an autonomous body under the Executive Branch of Government overseen by a nine-member Board of Directors appointed by the President from specific government agencies and the private sector. Part III of the Environmental Protection and Management Law (EPML) contains detailed procedures for the implementation of an Environmental Impact Assessment (EIA) program for Liberia. The EPA Act (Section 37) and EPML (Sections 6-33) require all public or private projects with a potentially significant impact on the environment to secure an EIA permit prior to commencement of the project

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS

APPROPRIATE)

N/A

4 Environmental Protection Agency (EPA) of the Republic of Liberia, November 26, 2002

USAID LIBERIA WASH

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

Construction activities have the potential to cause both direct and indirect adverse impacts on the environment. An example of a direct impact is the filling of a wetland to use as a project site.

Indirect impacts are induced changes in the environment, population, and use of land and environmental resources. Potential rehabilitation and construction impacts associated with small-scale construction activities are to be mitigated by applying guidance for environmentally sound design and management (ESDM), including guidance found in USAID’s Sector Environmental Guidelines at www.usaid.gov/environmental-procedures/ Environmental Protection and Management Law of Liberia.

TABLE 3A. POTENTIAL IMPACTS

Activity Potential environmental and social impacts

Construction and rehabilitation of new water supply structures

Construction:

● Construction typically necessitates clearing, grading, trenching, and other activities that can result in near-complete disturbance to the pre-existing landscape/habitat within the plot. If the plot contains or is adjacent to a permanent or seasonal stream/water body, grading and leveling can disrupt local drainage.

● The increased traffic, travel, and vehicle use associated with construction and rehabilitation of infrastructure may accelerate the rate of road degradation or increase traffic volumes.

● Site alteration may affect local hydrology, such as drainage patterns and water tables, which may alter access to water and result in increased flooding or higher runoff. Runoff removes the most fertile topsoil necessary for crop production and can lead to serious adverse consequences, including gully formation, siltation and sedimentation of water bodies, downstream flooding, and damage to productive infrastructure.

● Construction of facilities in sensitive areas (wetlands, estuaries, etc.) can destroy flora, fauna or their habitats, leading to loss of biodiversity, reduction of economic productivity associated with the essential ecosystem services, and loss of aesthetic and recreational value.

● Occupational and community health and safety hazards, including hazards from hand and power tool equipment, exposure to toxic substances, and general dangers of on-site construction.

● Construction activities are likely to temporarily contribute to increases in air and noise pollution.

● The introduction of construction crews to communities may result in public health impacts (e.g., introduction/spread of sexually-transmitted diseases).

● The siting and management of construction crew facilities (e.g., temporary housing when applicable, latrines, etc.) may result in small-scale land conversion, pollution of ground and surface water, or other environmental and social impacts.

● Material sourcing for use in construction activities (e.g., the

Latrine construction http://www.usaid.gov/environmental-procedures/

USAID LIBERIA WASH

use of borrow pits, the potential for unsustainably sourced timber products, siltation/sedimentation from illegal quarry activities) may result in harmful ecological impacts such as erosion and land degradation, pollution of land and water resources, or habitat destruction.

● Energy provision in relevant facilities (such as through the use of an on-site generator or the construction of transmission/distribution infrastructure) may disrupt ecological services, result in the emission of harmful pollutants, or otherwise cause negative environmental impacts.

Water Supply and Treatment

● Transmission of infectious disease and chronic toxicity (from poor water quality)

● Chronic/acute toxicity (agricultural/industrial chemical contamination)

● Chronic/acute toxicity (natural geologic sources, e.g., arsenic and fluoride)

Latrines

● Transmission of infectious disease associated with excreta

(diarrheal, parasitic, etc.)

● Acute/chronic toxicity and other health problems from consuming or contact with contaminated water (e.g., harmful algal blooms may cause acute or chronic toxic effects)

● Bacterial/microbial contamination of groundwater supply

● Fecal sludge entering water supplies

Illustrative Soclal Impact

● Inadequate planning of sanitation projects regarding privacy and convenience for women and children (e.g., providing separate sanitation facilities at schools)

USAID LIBERIA WASH

4.0 ENVIRONMENTAL DETERMINATIONS

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS

Pursuant to 22CFR216.3(c)(2)(iii). A Negative Determination with Condition is recommended for the Liberia IQC IEE portfolio activities. Therefore, implementing partners shall develop a comprehensive EMMP that will cover all sectors of their construction work, with specific mitigation and monitoring plans for all activities recording a negative determination with conditions. If project implementation takes advantage of sub grants/awards, partners shall adapt USAID’s “Supplemental Environmental Review Forms” for program activities to develop an internal environmental screening form for all project activities to ensure that potentially negative impacts are foreseen, and plans are developed for their mitigation. Based on the screening form, partners would be required to produce an Environmental Review Report for each activity. In addition, the Environmentally Sound Design and Management Capacity-Building for Partners and Programs in Africa (ENCAP) training programs for Mission Staff, implementing partners and GOL counterpart staff will be utilized.

4.2 CLIMATE RISK MANAGEMENT

Per guidance provided in ADS 201 Climate Risk Management for USAID Projects and Activities (201mal_101216), the activity design team conducted a CRM screening; technical guidance provided by the Mission Climate Integration Lead (CIL). USAID’s Climate Risk Screening and Management Tool (for activity design) It was made available to the technical team and used to assess the potential climate risks for the proposed activities. The analysis was reviewed as a team and the climate risks to its components were rated as low and moderate according to the CRM risk-rating guidance. Management options and potential adaptation measures were analyzed and refined using the climate matrix.

Using Liberia's Climate Risk Profile, we assessed the IQC activity using the Climate Risk Screening and Management Tool, assigned a risk rating and developed mitigation actions that could be included in our Activity design and implementation. We also identified Opportunities to Strengthen Climate Resilience in our activity. The most significant climate risks to the activity are discussed in the table below. The rationale behind the acceptance of any climate risks is also presented and justified.

Climate risks will be considered from the design to the implementation of this activity. It will be included in the solicitation document, and those risks will be included in the work plan during the activities implementation. This activity will implement a variety of solutions to mitigate climate-related risks to WASH systems. This may include reviewing and altering the location or design of a water point or latrine (to make them flood or cyclone -proof) or promoting renewable energy instead of diesel. Such changes can ensure that the water point or the latrine continues to be functional and accessible for decades, even after extreme weather events.

Engineering analysis preceding design activities must include consideration of climate change and its potential impacts on the location (siting), functionality and sustainability of resulting infrastructure and infrastructure services. Such analysis must include identification of relevant data sets and gaps, review of local building standards and codes for adequacy; and determination of safety factors or other https://www.climatelinks.org/resources/climate-risk-screening-management-tool https://www.climatelinks.org/resources/climate-risk-screening-management-tool

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measures of uncertainty that will be carried through design. The results of this analysis, including risks identified and how they are addressed, shall be documented.

Defined or Anticipated Project Elements

Climate Risks

Risk Rating

How Risks are Addressed at Project Level

Further Analysis and Actions for Activity Design/ Implementation

Opportunities to Strengthen Climate Resilience

Water quality and quantity

Rainfall variability and rising temperature lead to reduced water levels in shallow water, poor water quality, increased incidence of waterborne diseases, reduce runoff and flow, rising sea levels which lead to salt water intrusion in coastal aquifers

Moderate Introduce climate resilient

WASH

services

Improving urban and rural sanitation and sewage services to combat water pollution and water-borne diseases

Expand on-going efforts to develop municipal water treatment and distribution infrastructure.

Liberia has one of the highest rates of water resources per capita in Africa

Heavy rainfall could increase erosion, flooding and storms that could destroy WASH and sanitation infrastructure

Moderate Infrastructure will be designed with contingency plans to mitigate climatic disruption

Materials use for the infrastructure will take climate risk into account

WASH and Sanitation infrastructure

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5.0 CONDITIONS AND MITIGATION MEASURES

5.1 CONDITIONS

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

5.1.1 During Pre-Award:

5.1.1.1 Pre-Award Briefings: As feasible, the design team and/or the cognizant environmental officer(s) (e.g., MEO, REA, BEO) will provide a pre-award briefing for potential offerors on environmental compliance expectations/responsibilities at bidders’ conferences.

5.1.1.2 Solicitations: The design team, in coordination with the A/CO, will ensure solicitations include environmental compliance requirements and evaluation criteria. A/CO will ensure technical and cost proposal requirements include approach, staffing, and budget sufficient for complying with the terms of this IEE.

5.1.1.3 Awards: The A/COR, in coordination with the A/CO, will ensure all awards and sub-awards, include environmental compliance requirements.

5.1.2 During Post-Award:

5.1.2.1 Post-Award Briefings: The A/COR and/or the cognizant environmental officer(s) (e.g., MEO, REA, BEO) will provide post-award briefings for the IP on environmental compliance responsibilities.

5.1.2.3 Workplans and Budgeting: The A/COR will ensure the IP integrates environmental compliance requirements in work plans and budgets to comply with requirements, including EMMP implementation and monitoring.

5.1.2.4 Staffing: The A/COR, in coordination with the IP, will ensure all awards have staffing capacity to implement environmental compliance requirements.

5.1.2.5 Records Management: The A/COR will maintain environmental compliance documents in the official project/activity file and upload records to the designated USAID environmental compliance database system.

5.1.2.6 Host Country Environmental Compliance: The A/COR will ensure the IP complies with applicable and appropriate host country environmental requirements unless otherwise directed in writing by USAID. However, in the case of a conflict between the host country and USAID requirements, the more stringent shall govern.

5.1.2.7 Work Plan Review: The A/COR will ensure the IP verifies, at least annually or when activities are added or modified, that activities remain with the scope of the IEE.

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Activities outside of the scope of the IEE cannot be implemented until the IEE is amended.

5.1.2.8 IEE Amendment: If new activities are introduced or other changes to the scope of this IEE occur, an IEE Amendment will be required.

5.1.2.14 USAID Monitoring Oversight: The A/COR or designee, with the support of the cognizant environmental officer(s) (e.g., MEO, REA, BEO), will ensure monitoring of compliance with established requirements (e.g., by desktop reviews, site visits, etc.).

5.1.2.16 Environmental Compliance Mitigation and Monitoring Plan: The A/COR will ensure the IP develops, obtains approval for, and implements Environmental Mitigation and Monitoring Plans (EMMPs) that are responsive to the stipulated environmental compliance requirements.

5.1.2.17 Environmental Compliance Reporting: The A/COR will ensure the IP includes environmental compliance in regular project/activity reports, using indicators as appropriate; develops and submits the Environmental Mitigation and Monitoring Reports (EMMRs); and completes and submits a Record of Compliance (RoC) describing their implementation of EMMP requirements in conjunction with the final EMMR or at the close of sub activities (as applicable). And where required by Bureaus or Missions, ensure the IP prepares a closeout plan consistent with contract documentation for A/COR review and approval that outlines responsibilities for end-of-project operation, the transition of other operational responsibilities, and final EMMR with lessons learned.

5.1.2.18 Corrective Action: When noncompliance or unforeseen impacts are identified, IPs notify the A/COR, place a hold on activities, take corrective action, and report on the effectiveness of corrective actions. The A/COR initiates the corrective action process and ensures the IP completes and documents their activities. Where required by Bureaus or Missions, ensure Record of Compliance is completed.

5.2 AGENCY CONDITIONS

5.2.1 Sub-contract Screening: The A/COR will ensure the IP uses an Environmental Screening Tool to screen any sub-grant applications and to aid in the development of EMMPs.

5.2.2 Programmatic IEEs (PIEE): PIEEs stipulate requirements for additional environmental examination of new or country specific projects/activities. The A/COR of any project/activity being implemented under a PIEE will ensure appropriate reviews are conducted, typically through a Supplemental IEE, and approved by the cognizant BEO.

5.2.3 Supplemental IEEs (SIEEs): An SIEE will be prepared for any new project/activity being planned which fall under a PIEE. The SIEE will provide more thorough

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analysis of the planned activities, additional geographic context and baseline conditions as well as specific mitigation and monitoring requirements.

5.2.4 Other Supplemental Analyses: The A/COR will ensure supplemental environmental analyses that are called for in the IEE are completed and documented.

5.2.5 Resolution of Deferrals: If a deferral of the environmental threshold determination was issued, the A/COR will ensure that the appropriate 22CFR216 environmental analysis and documentation is completed and approved by the BEO before the subject activities are implemented.

5.2.6 Positive Determination: If a Positive Determination threshold determination was made, the A/COR will ensure a Scoping Statement, and if required an Environmental Assessment (EA), is completed and approved by the BEO before the subject activities are implemented.

5.2.7 Compliance with human subject research requirements: The AM, A/COR shall assure that the IP and sub-awardees, -grantees, and -contractors demonstrate completion of all requirements for ethics review and adequate medical monitoring of human subjects who participate in research trials carried out through this IEE and ensure appropriate records are maintained. All documentation demonstrating completion of required review and approval of human subject trials must be in place prior to initiating any trials and cover the period of performance of the trial as described in the research protocol.

5.3 MITIGATION MEASURES

The mitigation measures presented in this section constitute the minimum required based on available information at the time of this IEE and the environmental analysis in Section 4. These measures shall provide general direction for completing the project/activity Environmental Mitigation and Monitoring Plan (EMMP) and/or the EA and PERSUAP, if required.

TABLE 5A. SUMMARY OF MITIGATION MEASURES

Activity Mitigation Measure(s)

Construction and rehabilitation of new water supply structures

• Assess water quality upstream and downstream to determine if water is safe to drink and to establish a baseline so that any future degradation can be detected, prior to commissioning.

• Assess quality of groundwater during investigation and confirm upon commissioning of system.

• Develop and implement water quality assurance plan (WQAP).

• Undertake water quality tests (physiochemical and bacteriological) in accordance with WQAP.

• Consider how the project will impact the water table level, USAID LIBERIA WASH particularly in the context of climate change.

• Use fencing or equivalent to keep livestock from grazing upgradient of the water supply and drinking from the water source.

• Ensure sanitation facilities are sited an appropriate distance away from source, at least 30 m.

• Site wells a safe distance from any waste dumps or chemical or pesticide storage sites.

• Periodically inspect area around the source for changes in land use that could introduce contamination.

• Perform an assessment of the watershed and aquifer to prevent over-pumping and contamination for long-term sustainability.

• Maintenance of the borehole equipment and treatment unit

• Provide hygiene and sanitation facilities a sufficient distance (e.g., 50 m) away from the borehole at an appropriate site.

• Community education and outreach on proper handling of water after drawing it

• Calculate yield and extraction rates in relation to other area water uses and available supply. Monitor water levels to detect overdrawing.

For water treatment, as part of the WQAP the chlorinator capacity shall be such that a free chlorine residual of at least 2 mg/l can be maintained in the water once all demands are met after an effective contact time of at least 30 minutes, when maximum flow rate coincides with water supply and sanitation.

Social Mitigation Measures

• Ensure all beneficiary viewpoints are included in project planning by conducting community forums and stakeholder engagement meetings.

• Devote adequate attention to identifying and addressing social barriers to using latrines.

• Water use planning addresses equitable distribution among beneficiaries.

• Community members of all beneficiary groups are represented in water use/management planning and operation.

• Ensure water and sanitation access benefits both genders equally and that women are not carrying the largest management burden.

Latrine construction (and • Evaluate depth to water table, including seasonal fluctuations, USAID LIBERIA WASH operation) groundwater hydrology, and any changes expected due to climate change.

• Pit latrines should not be installed where the water table is shallow or where the composition of the overlying deposits makes groundwater vulnerable to contamination. Replace pit latrine with a mounded latrine or other alternative.

• Latrines should be sited a minimum of 30 m from water sources.

• Bottom of the pit should be 2 m above groundwater level.

• Minimum of 30 m distance between pit and water source.

• Ensure that a reliable system for safely removing fecal sludge and transporting off-site for treatment is available. Ensure that collected fecal sludge is adequately treated and not directly applied to fields or otherwise improperly disposed of.

• Install hand wash stations near latrines (following mitigation measures described for water supplies above).

• Ensure that a reliable system is used for safely emptying latrines, toilets, and septic tanks and transporting the collected material off-site for treatment.

• Ensure that collected material is adequately treated to international standards and not directly applied to fields or otherwise disposed of improperly.

• Properly decommission pit latrines. Do not leave pits open. Fill in unused capacity with rocks or soil.

• Include focus on proper use and maintenance of the system as part of behavior change and education program.

• Use the ventilated improved pit latrine design (as appropriate) that traps insect vectors.

• Establish water committee to oversee maintenance and ensure drinking water is protected.

Social Mitigation Measures

• Ensure all beneficiary viewpoints are included in project planning by conducting community forums and stakeholder engagement meetings.

• Plan separate latrines for each gender. Seek input from women in the community on where to site facilities so they feel comfortable using them.

• Devote adequate attention to identifying and addressing social barriers to using latrines.

• Water use planning addresses equitable distribution among

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beneficiaries.

• Community members of all beneficiary groups are represented in water use/management planning and operation.

• Ensure water and sanitation access benefits both genders equally and that women are not carrying the largest management burden.

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6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION

The determinations recommended in this document apply only to projects/activities and sub-activities described herein. Other projects/activities that may arise must be documented in either a separate IEE, an IEE amendment if the activities are within the same project/activity, or other type of environmental compliance document and shall be subject to an environmental analysis within the appropriate documents listed above.

Other than projects/activities determined to have a Positive Threshold Determination, it is confirmed that the…