J.14 Signed IEE.pdf

TRACKING ID: #

BUREAU/MISSION/PROJECT 1

INITIAL ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY DATA

Project/Activity Name: EDUCATION, DEVELOPMENT OBJECTIVE 4:

Better-Educated Liberians

Amendment (Y/N): Yes Geographic Location(s) (Country/Region): Liberia Implementation Start/End: September 30, 2017/ March 30, 2022 Solicitation/Contract/Award Number:

Implementing Partner(s): Multiple Tracking ID/link: Liberia Education DO4 IEE.09.22.2017 Tracking ID/link of Related RCE/IEE (if any): School for the Blind Girls Dormitory Construction

Project Education, DO 4: Better-Educated Liberians Excellence in Higher Education for Liberian Development

(EHELD)

Tracking ID/link of Other, Related Analyses: Liberia Vertical Infrastructure Construction Oversight (VICO) RCE please see:

http://gemini.info.usaid.gov/repository/pdf/50228.pdf

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

Liberia

Funding Operating Unit(s):

(e.g. Mission or Bureau or Office)

Liberia

Funding Account(s):

Funding Amount: about $150 Million Amendment Funding Date: Amendment Funding Amount:

Other Affected Unit(s):

Lead BEO Bureau: Brian Hirsch Prepared by: Ara Chea, Education Office

Date Prepared: September 20, 2017

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: x Categorical Exclusion Initial Environmental Examination x Amendment Deferral

Environmental Determination(s): x Negative Determination Positive Determination

Initial Environmental Examination Expiration Date:

September 30, 2022

Additional Analyses/Reporting Required: Climate Risk Management, see Sect. 4 Climate Risks Identified (#): Low ___x___ Moderate ______ High ______ Climate Risks Addressed (#): Low ___x___ Moderate ______ High ______

THRESHOLD DECISION MEMO AND SUMMARY OF FINDINGS

PURPOSE AND SCOPE OF THE INITIAL ENVIRONMENTAL EXAMINATION

The purpose of this amendment is to extend the IEE completion date to March 30, 2022 and include new activities that were not covered under the original IEE.

Based on the activities descriptions enumerated in Section 1.3 of this IEE, this IEE provides the first review of the reasonably foreseeable effects on the environment, as well as recommended Threshold Decisions, for activities across the entire portfolio. This IEE provides a brief statement of the factual basis for a Threshold Decision as to whether an Environmental Assessment or an Environmental Impact Statement are required for the activities managed under this program.

All other aspects of the above-referenced IEE are unchanged. Further, all restrictions and requirements enumerated in Section 4 of the original IEE are applicable to the activities encompassed by this Amendment.

PROJECT/ACTIVITY SUMMARY

Read Liberia activity is designed to increase students’ literacy skills through school-based early grade reading training for teachers, targeted capacity development for county education and district education officers, and principals, distribution of textbooks and learning materials and promotion of policy development and messaging to foster a reading culture. Read Liberia will also contribute technical assistance to the development of new kindergarten learning, teaching materials and resource development.

An Impact Evaluation will be designed to assess the causal impact of the Read Liberia activity on the reading performance of second grade students in Liberia. The evaluation will be informed by the baseline data collected before the start of the Read Liberia activity and the end-line data collected in 2020.

Accelerated Quality Education for Liberian Children (AQE) goal is to provide vulnerable and out- of- school populations ages 8-15 with increased equitable access to education and support to enable learners to transition to formal education. It also aims to: increase enrollment of out-of-school, institutionalize ALP regulatory framework, increase eligibility of learners to transition to formal education, decrease sexual and gender based violence in schools and build PTA capacity.

Learning Links will provide access to quality literacy and numeracy learning resources to enable pregnant girls to continue learning while they are not in school. The activity will also provide trained tutor-mentors, the ABE curriculum, SMS-based evaluations, and micro-incentives to address a range of challenges. Learning Links will also provide social support through access to counselors and caseworkers who will work individually with girls to assess their psychosocial needs and develop an individual plan for each. The activity will operate in three locations in Bong County.

New Youth for out-of-school youth ages 15-35 will focus on building the capacity of local Liberian organizations to deliver integrated youth education and livelihoods programs to youth; expanding the reach of work readiness activities and support for youth self-employment; and developing integrated youth centers to offer ABE, livelihoods, health and other interventions, possibly on a fee for service model.

Program Evaluation and Assessment Activities: Several program and impact evaluations, as well as descriptive studies and operational research data collection are planned for the Education portfolio. A reading mid-term and final program evaluations, quantitative demographic and opinion surveys may be undertaken as part of descriptive and operational research toward understanding potential barriers to out of school learners. The Project will also conduct a Rapid Education Risk Assessment (RERA) to obtain a snapshot of how education systems, learners, families, and their communities interact with a dynamic, multiple-risk environment. The RERA integrates key elements of conflict analysis, disaster risk analysis, and resilience analysis. The RERA supports all stages of the USAID program cycle and will be implemented within an existing USAID activity; utilize qualitative data collection and analysis through in-depth interviews and small focus group discussions.

ENVIRONMENTAL DETERMINATIONS

For the purposes of environmental review, current and anticipated activities in the Education portfolio are grouped into the following classes of activities:

1. Curricula and Learning/Teaching Materials and Resource Development

2. Teacher/Facilitator Training and Faculty Development

3. Standards and Testing

4. Student Services

5. Outreach, Livelihood Linkages, Advocacy, and Community Mobilization

6. Integration of Innovative Technologies

7. Program Learning, Assessment, and Evaluation (including pilots and special studies)

8. Small-scale Refurbishment Activities

Detailed environmental determinations (and conditions, where applicable) per class of activity is provided under section 4 of this IEE.

TABLE 1: ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion Citation (if applicable)

Negative Determination

Positive Determination Deferral1

Curricula and Learning/Teaching Materials and Resources Development;

General education curricula, materials, and resource development X Teacher/Facilitator Training and Faculty Development X Standards and Testing X

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.

Institutional Capacity Building, Financial Management, Planning, and Policy X Outreach, Livelihood Linkages, Advocacy, and Community Mobilization X Integration of Innovative Technologies X Program Learning Assessment and Evaluation activities (including pilots, special studies, etc.) X Small-scale refurbishment X

CLIMATE RISK MANAGEMENT

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 to include preparation and implementation of schools emergency plans, involving Students, Teachers, Parents, and Communities, Practicing Early Warning, Simulation Drills, and Evacuation for expected and recurring disasters and implementing improved ventilation in schools utilizing improved energy technologies.

BEO SPECIFIED CONDITIONS OF APPROVAL

NA

IMPLEMENTATION

In addition to the specific conditions enumerated in Section 3, the negative determinations recommended in this IEE are contingent on full implementation of the following general monitoring and implementation requirements:

1. IP Briefings on Environmental Compliance Responsibilities. The Education Team shall provide each implementing partner (IP) with a copy of this IEE. Each IP shall be briefed on their environmental compliance responsibilities by their COR/AOR. Such briefings will identify the IEE conditions applicable to each IP’s activities.

2. Development of an EMMP. Each IP whose activities are subject to one or more conditions set out in section 3 of this IEE shall develop and provide to the COR/AOR for review and approval an Environmental Mitigation and Monitoring Plan (EMMP) that clearly documents how their project will implement and verify all IEE conditions and mitigation measures that apply to their activities.

These EMMPs shall identify how the IP will ensure that IEE conditions that apply to activities supported under sub-contracts and sub-grants are implemented. In the case of large sub-grants or sub-contracts, the IP may elect to require the sub-grantee/sub-contractor to develop their own EMMP. A sample EMMP format is included as ANNEX A to this IEE.

3. Integration and implementation of EMMP. Each IP shall integrate their EMMP into their project work plan and budgets, implement the EMMP, and report on its implementation and findings as an element of regular project performance reporting.

IPs shall ensure that sub-contractors and sub-grantees integrate implementation of IEE conditions, where applicable, into their own project work plans and budgets, and report on their implementation and findings as an element of sub-contract or grant performance reporting.

4. Integration of compliance responsibilities in prime and sub-contracts and grant agreements.

a. The Education Team Leader shall ensure that any future contracts or agreements for implementation of a project, and/or significant modification(s) to current contracts/agreements shall reference and require compliance with the conditions set out in this IEE, as required by ADS 204.3.4.a.6 and ADS 303.3.6.3.e.

b. IPs shall ensure that future sub-contracts and sub-grant agreements, and/or significant modification(s) to existing agreements reference and require compliance with relevant elements of these conditions.

5. Assurance of sub-grantee and sub-contractor capacity and compliance. IPs shall ensure that sub-grantees and sub-contractors have the capacity to implement the relevant requirements of this IEE. The IP shall, as and if appropriate, provide training to sub-grantees and sub-contractors in their environmental compliance responsibilities and in environmentally sound design and management (ESDM) of their activities.

6. New or modified activities. As part of its work plan and all annual work plans thereafter, IPs, in collaboration with their COR/AOR, shall review all on-going and planned activities to determine if they are within the scope of this IEE.

If any IP adds new activities or makes substantial modifications to existing activities, an amendment to this IEE addressing these activities shall be prepared for USAID review and approval. No such new activities shall be undertaken prior to formal approval of this amendment.

Any ongoing activities found to be outside the scope of the approved Regulation 216 environmental documentation shall be halted until an amendment to the documentation is submitted and written approval is received from USAID.

7. Compliance with Host Country Requirements. Nothing in this IEE substitutes for or supersedes IP, sub-grantee, and sub-contractor responsibility for compliance with all applicable host country laws and regulations. The IP, sub-grantees, and sub-contractors must comply with host country environmental regulations unless otherwise directed in writing by USAID; however, in case of conflict between host country and USAID regulations, the latter shall govern.

8. Government-to-government (G2G) assistance. In keeping with USAID Forward, investment in country-led plans is an important value, which may include consideration of sector program assistance (SPA) or other government-to-government assistance. USAID/Liberia may need to obtain Authorization for Use of Partner Country Systems (AUPCS) – a requirement for G2G assistance specified in ADS 220 Use of Reliable Partner Country Systems for Direct Management and Implementation of Assistance. This will include certification of the effectiveness of Liberia’s environmental assessment procedures, policy & legislative framework. This should be harmonized with the expectations of other sector donors (World Bank, EU, etc.), in line with the Paris Declaration of Aid Effectiveness.

As required by ADS 204.5.4, the Education Team will actively monitor and evaluate whether the conditions of this IEE are being implemented effectively and whether there are new or unforeseen consequences arising during implementation that were not identified and reviewed in this IEE. If new or unforeseen consequences arise during implementation, the team will suspend the activity and initiate appropriate further review in accordance with 22 CFR 216. USAID monitoring activities shall include regular site visits.

BUREAU/MISSION/PROJECT 8

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE AND SCOPE OF IEE

The purpose of this amendment is to extend the IEE completion date to March 30, 2022 and include new activities that were not covered under the original IEE.

Based on the activities descriptions enumerated in Section 1.3, 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.

1.2 PROJECT/ACTIVITY OVERVIEW

The USAID/Liberia, Education Access, Quality and Governance Project/Portfolio’s purpose is to increase educational achievement in Liberia by improving the educational opportunities provided to Liberian children, youth, and young adults. Activities implemented under the current program address the lack of access to primary schooling, create alternative basic education programs especially for rural children, girls, overage and out of school youth, increase retention, attendance, and completion in these programs.

The Portfolio will focus on systems strengthening, capacity building, and achieving measurable and sustainable educational outcomes, both in the short- and medium-term. In the transition from crisis response to development, Development Objective 4 supports improved access to education, the quality of teaching and learning, and the human and institutional capacity to provide those services.

1.3 PROJECT/ACTIVITY DESCRIPTION

Read Liberia activity is designed to increase students’ literacy skills through school-based early grade reading training for teachers, targeted capacity development for county education and district education officers, and principals, distribution of textbooks and learning materials and promotion of policy development and messaging to foster a reading culture. Read Liberia will also contribute technical assistance to the development of new kindergarten learning, teaching materials and resource development.

An Impact Evaluation will be designed to assess the causal impact of the Read Liberia activity on the reading performance of second grade students in Liberia. The evaluation will be informed by the baseline data collected before the start of the Read Liberia activity and the endline data collected in 2020.

Accelerated Quality Education for Liberian Children (AQE) goal is to provide vulnerable and out- of- school populations ages 8-15 with increased equitable access to education and support to enable learners to transition to formal education. It also aims to: increase enrollment of out-of-school, institutionalize ALP regulatory framework, increase eligibility of learners to transition to formal education, decrease sexual and gender based violence in schools and build PTA capacity.

Learning Links will provide access to quality literacy and numeracy learning resources to enable girls to continue learning while they are not in school. The activity will also provide trained tutor-mentors, the ABE curriculum, SMS-based evaluations, and micro-incentives to address a range of challenges.

Learning Links will also provide social support through access to counselors and caseworkers who will work individually with girls to assess their psychosocial needs and develop an individual plan for each.

The activity will operate in three locations in Bong County.

New Youth for out-of-school youth ages 15-35 will focus on building the capacity of local Liberian organizations to deliver integrated youth education and livelihoods programs to youth; expanding the reach of work readiness activities and support for youth self-employment; and developing integrated youth centers to offer ABE, livelihoods, health and other interventions, possibly on a fee for service model.

Program Evaluation and Assessment Activities.

Several program and impact evaluations, as well as descriptive studies and operational research data collection are planned for the Education portfolio. A reading mid-term and final program evaluations, quantitative demographic and opinion surveys may be undertaken as part of descriptive and operational research toward understanding potential barriers to out of school learners. The Project will also conduct a Rapid Education Risk Assessment (RERA) to obtain a snapshot of how education systems, learners, families, and their communities interact with a dynamic, multiple-risk environment. The RERA integrates key elements of conflict analysis, disaster risk analysis, and resilience analysis. The RERA supports all stages of the USAID program cycle and will be implemented within an existing USAID activity; utilize qualitative data collection and analysis through in-depth interviews and small focus group discussions.

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.2 The Upper Guinean Forest ecosystem and is identified by Conservation International as a “Biodiversity Hotspot.”

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

The Environmental Threats and Opportunities Assessment (ETOA) completed by USAID/Liberia in late 20083 identified a number of 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)

Programs and resources will focus predominantly on six of Liberia’s 15 counties that have been identified by the Government of Liberia as priority Development Corridors: Bong, Grand Bassa, Lofa, Nimba, Montserrado, and Margibi. By concentrating efforts in these counties, the program will reach 75 percent of Liberians—of whom three quarters live below the poverty line—and exploit synergies across programs to maximize results.

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.

Environmental Threats and Opportunities Assessment (ETOA): USAID/Liberia decided an Environmental Threats and Opportunities Assessment (ETOA) was warranted and was completed in September 2008. The ETOA describes the range of environmental impacts from human activities across the spectrum of sectors: green (forests, agricultural systems), brown (urban, industrial systems) and blue

3 Liberia Environmental Threats and Opportunities Assessment (ETOA): Final Report. September 2008. Available online at: http://www.encapafrica.org/documents/biofor/Liberia2008.pdf

(marine and freshwater systems) and makes recommendations. The activities of Liberia’s government institutions to manage and conserve forests and biodiversity are constrained by a number of factors including dependence on foreign expertise and resources, a decimated infrastructure and weak administration, lack of qualified staff, shortage of information for decision making, overlapping mandates, weak law enforcement and poor coordination between government organizations, donors and nongovernmental organizations, and lack of direct financial support.

Implementing partners shall develop a comprehensive EMMP for each project, 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.

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)

NA

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK5

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 http://www.usaidgems.org/bestPractice.htm, Environmental Protection and Management Law of Liberia, 4 Environmental Protection Agency (EPA) of the Republic of Liberia, November 26, 2002 5 Includes analysis of environmental and social adopted November 26, 2002 and the IFC environmental, health and safety guidelines at www.ifc.org/ehsguidelines.

In addition, construction oversight and assurance of the implementation of environmental safeguards for small construction is being provided by independent A&E contractors under the Liberia Vertical Infrastructure Construction Oversight (VICO) contract.

ACTIVITY 1: ACCELERATED QUALITY EDUCATION FOR LIBERIAN CHILDREN (AQE)

While construction itself has a well-known set of potential adverse impacts, the activity described above involves substantially less activities than construction, as these activities are limited to small-scale renovation and/or refurbishment. Current structures have no historic, cultural, or social importance.

No new road construction is envisioned under the education portfolio.

Renovations carried out under the AQE contract will entail only minor renovations. The work to be performed will also include the purchase and placement of furniture in existing structures. The work will be of short duration and will not necessitate the need for camps to be built to house workers. No heavy equipment (e.g., large tractors or trucks) will be employed in the renovations.

TABLE 2. POTENTIAL IMPACTS

Project/Activity Potential environmental and social impacts Sub-Activity 1: Small scale refurbishment as roof, classroom, and latrine rehabilitation, painting, installation of doors, locks and windows.

Noise pollution

- During construction activities, noise may be caused by the operation of demolition, earth moving and excavation machines, generators, concrete mixers and cranes. The increased noise level can negatively impact construction workers if appropriate worker safety measures are not implemented.

Worker safety

- Typical health and safety risks to construction workers include falls, injury from falling objects, crush injuries from collapses and heavy equipment, flying debris, extreme heat stress brought on by high temperatures and humidity, and exposures to toxic materials including solvents, cement dust, lead and asbestos. Occupational injuries can permanently deprive construction workers of the ability to earn and livelihood and are often fatal.

Latrine Rehabilitation

- In operation, latrines can contaminate shallow groundwater and wells and, when not well maintained or of an open-pit design, can be the source of multiplication of flies, mosquitoes, spread of diseases, and foul odors. (Properly operated KVIP toilets, which are identified by as an intervention focus, address insect control and odor, though they may still contaminate groundwater.)

More specifically, poorly designed sanitation facilities can lead to insect-borne diseases: There are two groups to consider. Firstly, culex mosquitoes, which do not transmit malaria but can transmit filariasis, breed extensively in septic tanks and flooded latrines.

Secondly, flies and cockroaches often thrive on excreta and have been implicated in some transmission of fecal-oral disease.

Mosquitoes, flies, and cockroaches all constitute a great nuisance, and poor urban households have consistently been shown to spend substantial amounts of their limited household income on using control coils and nets.

4.0 ENVIRONMENTAL DETERMINATIONS

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS

For the purposes of environmental review and recommended determination, current and anticipated activities in the Education portfolio are grouped into the following classes of activities:

1. Curricula and Learning/Teaching Materials and Resource Development

2. Teacher/Facilitator Training and Faculty Development

3. Standards and Testing

4. Student Services

5. Outreach, Livelihood Linkages, Advocacy, and Community Mobilization

6. Integration of Innovative Technologies

7. Program Learning, Assessment, and Evaluation (including pilots and special studies)

8. Small-scale Refurbishment Activities

In this section, the potential impacts of these classes of activities are analyzed, and on this basis, recommended determinations made. In most cases, a categorical exclusion is recommended pursuant to 22 CFR 216.2(c)(2)(i). One class of activity has been identified as meeting a threshold for a Negative Determination with Conditions—activity 8 identified above. For this class of activity, a justification for a negative determination with conditions is provided and possible mitigation measures identified.

TABLE 3: ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion Citation (if applicable)

Negative Determination

Positive Determination Deferral

Curricula and Learning/Teaching Materials and Resources Development;

General education curricula, materials, and resource development X Teacher/Facilitator Training and Faculty Development X Standards and Testing Institutional Capacity Building, Financial Management, Planning, and Policy X Outreach, Livelihood Linkages, Advocacy, and Community Mobilization X Integration of Innovative Technologies X Program Learning Assessment and Evaluation X activities (including pilots, special studies, etc.)

Small-scale refurbishment X

BUREAU/MISSION/PROJECT 15

4.2 CLIMATE RISK MANAGEMENT

Using the Liberia’s Climate Risk Profile, we assessed the USAID/Liberia DO4 Education Portfolio using the Climate Risk Screening and Management Tool, assigned a risk rating and developed mitigation actions that could be included in our portfolio design and implementation. We also identified Opportunities to Strengthen Climate Resilience in our portfolio.

TABLE 4. PROJECT CLIMATE RISK MANAGEMENT SUMMARY TABLE

Defined or Anticipated Project Elements

(Purpose/Sub-purpose, Area of Focus, or Activity/ Mechanism, etc.)

Climate Risks

List key risks related to the project elements identified through either the strategy- or project-level climate risk assessment.

Risk Rating

Low/Moderate/ High

How Risks are Addressed at Project Level

Describe how risks have been addressed at the project level. If a decision has been made to accept the risk, briefly explain why.

Further Analysis and Actions for Activity Design/ Implementation

Describe CRM measures to be integrated into activity design or implementation, including additional analysis, if applicable.

Opportunities to Strengthen Climate Resilience

Describe opportunities to achieve development objectives by integrating climate resilience or mitigation measures.

Small-scale refurbishment

Increased Temperatures

Low Classrooms designed with increased ventilation

Employ renewable energy technologies in new designs.

Consider building to withstand tropical storms, increased rainfall and flooding.

Prepare schools emergency plans.

Involve Students, Teachers, Parents, and Communities in Practicing Early Warning, Simulation Drills, and Evacuation for Expected and Recurring Disasters

Changes in amount and duration of rainfall

Low Build schools closer to homes.

Consider transportation for students.

Sea level rise Low Relocate school buildings away from coastlines.

Designate alternative classrooms or school sites.

BUREAU/MISSION/PROJECT 16

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. USAID will ensure that applicable requirements are met.

1. IP Briefings on Environmental Compliance Responsibilities. The Education Team shall provide each implementing partner (IP) with a copy of this IEE. Each IP shall be briefed on their environmental compliance responsibilities by their COR/AOR. Such briefings will identify the IEE conditions applicable to each IP’s activities.

2. Development of an EMMP. Each IP whose activities are subject to one or more conditions set out in section 3 of this IEE shall develop and provide to the COR/AOR for review and approval an Environmental Mitigation and Monitoring Plan (EMMP) that clearly documents how their project will implement and verify all IEE conditions and mitigation measures that apply to their activities.

These EMMPs shall identify how the IP will ensure that IEE conditions that apply to activities supported under sub-contracts and sub-grants are implemented. In the case of large sub-grants or sub-contracts, the IP may elect to require the sub-grantee/sub-contractor to develop their own EMMP. A sample EMMP format is included as ANNEX A to this IEE.

3. Integration and implementation of EMMP. Each IP shall integrate their EMMP into their project work plan and budgets, implement the EMMP, and report on its implementation and findings as an element of regular project performance reporting.

IPs shall ensure that sub-contractors and sub-grantees integrate implementation of IEE conditions, where applicable, into their own project work plans and budgets, and report on their implementation and findings as an element of sub-contract or grant performance reporting.

4. Integration of compliance responsibilities in prime and sub-contracts and grant agreements.

a. The Education Team Leader shall ensure that any future contracts or agreements for implementation of a project, and/or significant modification(s) to current contracts/agreements shall reference and require compliance with the conditions set out in this IEE, as required by ADS 204.3.4.a.6 and ADS 303.3.6.3.e.

b. IPs shall ensure that future sub-contracts and sub-grant agreements, and/or significant modification(s) to existing agreements reference and require compliance with relevant elements of these conditions.

5. Assurance of sub-grantee and sub-contractor capacity and compliance. IPs shall ensure that sub-grantees and sub-contractors have the capacity to implement the relevant requirements of this IEE. The IP shall, as and if appropriate, provide training to sub-grantees and sub-contractors in their environmental compliance responsibilities and in environmentally sound design and management (ESDM) of their activities.

6. New or modified activities. As part of its work plan and all annual work plans thereafter, IPs, in collaboration with their COR/AOR, shall review all on-going and planned activities to determine if they are within the scope of this IEE.

If any IP adds new activities or makes substantial modifications to existing activities, an amendment to this IEE addressing these activities shall be prepared for USAID review and approval. No such new activities shall be undertaken prior to formal approval of this amendment.

Any ongoing activities found to be outside the scope of the approved Regulation 216 environmental documentation shall be halted until an amendment to the documentation is submitted and written approval is received from USAID.

7. Compliance with Host Country Requirements. Nothing in this IEE substitutes for or supersedes IP, sub-grantee, and sub-contractor responsibility for compliance with all applicable host country laws and regulations. The IP, sub-grantees, and sub-contractors must comply with host country environmental regulations unless otherwise directed in writing by USAID; however, in case of conflict between host country and USAID regulations, the latter shall govern.

8. Government-to-government (G2G) assistance. In keeping with USAID Forward, investment in country-led plans is an important value, which may include consideration of sector program assistance (SPA) or other government-to-government assistance. USAID/Liberia may need to obtain Authorization for Use of Partner Country Systems (AUPCS) – a requirement for G2G assistance specified in ADS 220 Use of Reliable Partner Country Systems for Direct Management and Implementation of Assistance. This will include certification of the effectiveness of Liberia’s environmental assessment procedures, policy & legislative framework. This should be harmonized with the expectations of other sector donors (World Bank, EU, etc.), in line with the Paris Declaration of Aid Effectiveness.

As required by ADS 204.5.4, the Education Team will actively monitor and evaluate whether the conditions of this IEE are being implemented effectively and whether there are new or unforeseen consequences arising during implementation that were not identified and reviewed in this IEE. If new or unforeseen consequences arise during implementation, the team will suspend the activity and initiate appropriate further review in accordance with 22 CFR 216. USAID monitoring activities shall include regular site visits.

5.2 AGENCY CONDITIONS

5.2.1 ACTION-SPECIFIC CONDITIONS

N/A

5.2.2. MANAGEMENT CONDITIONS

N/A

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.

PROJECT/ACTIVITY 1: ACCELERATED QUALITY EDUCATION FOR LIBERIAN CHILDREN

(AQE)

TABLE 5. SUMMARY OF MITIGATION MEASURES FOR PROJECT/ACTIVITY 1

Project/Activity Mitigation Measures

Construction, in general Engage independent construction management contractor under the VICO contract to monitor and implement environmental safeguards

Construction crews and camps Explore off-site accommodation for crew, including in existing hotels or lodgings (P&D) (C) Keep camp size to a minimum. Require that crew preserve as much vegetation as possible, e.g., by creating defined footpaths (P&D) (C)

Provide temporary sanitation on site, e.g., pit latrine (assuming the water table is low enough, with soil and geology of appropriate composition) (P&D) (C)

Use local or regional labor, if possible. Screen potential crew members for HIV/AIDS and tuberculosis. Provide education and strict guidelines regarding contact with local residents, and enforce guidelines (P&D) (C)

Set guidelines prohibiting poaching and collection of plants/wood with meaningful consequences for violation such as termination of employment.

Provide adequate quantities of food and cooking fuel; both should be of good quality (C)

Consider climate impacts and the needs of the local population

Use of hazardous materials Prevent dumping of hazardous materials. Burn waste materials that are not reusable/readily recyclable IF they do not contain heavy metals and are flammable (P&D) (C).

Investigate and use less toxic alternative products (P&D) (C)

General Occupational Health and Safety Issues

Follow host country occupational safety and health standards for construction. Under no circumstances, however, should construction health and safety practices be less protective than the minimum practices specified in the Visual Field Guide for Small-Scale Construction.

Renovation of latrines Good-practice design standards must be implemented for new construction and rehabilitation works, generally consistent with USAID’s Sector Environmental Guidelines: Water Supply & Sanitation:

http://www.usaidgems.org/Sectors/watsan.htm.

These standards must be specified in the EMMP and include provisions to prevent contamination of water supplies, appropriate choice of latrine type given local environmental conditions (e.g. improved pit latrines are rarely suitable in locations where the water table is high), provision of handwash stations, and development and implementation of a system for ongoing latrine cleaning and maintenance.

Capacity-building in equipment/system maintenance must be co-programmed with renovation/construction of small-scale sanitation infrastructure.

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 Decision, it is confirmed that the projects/activities described herein do not involve actions normally having a significant effect on the environment, including those described in 22CFR216.2(d).

In addition, other than projects/activities determined to have a Positive Threshold Decision and/or a pesticide management plan (PERSUAP), it is confirmed that the projects/activities described herein do not involve any actions listed below. Any of the following actions would require additional environmental analyses and environmental determinations:

Support project preparation, project feasibility studies, or engineering design for activities listed in §216.2(d)(1);

Affect endangered and threatened species or their critical habitats per §216.5, FAA 118, FAA 119;

Provide support to extractive industries (e.g. mining and quarrying) per FAA 117;

Promote timber harvesting per FAA 117 and 118;

Lead to new construction, reconstruction, rehabilitation, or renovation work per §216.2(b)(1);

Support agro-processing or industrial enterprises per §216.1(b)(4);

Provide support for regulatory permitting per §216.1(b)(2);

Lead to privatization of industrial facilities or infrastructure with heavily polluted property per

§216.1(b)(4);

Procure or use genetically engineered organisms per §216.1(b)(1); and/or Assist the procurement (including payment in kind, donations, guarantees of credit) or use

(including handling, transport, fuel for transport, storage, mixing, loading, application, clean-up of spray equipment, and disposal) of pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials. Pesticides cover all insecticides, fungicides, rodenticides, etc. covered under the Federal Insecticide, Fungicide, and Rodenticide Act per §216.2(e) and §216.3(b).

7.0 REVISIONS

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 A/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.

ATTACHMENTS:

1. REFERENCE DOCUMENTS