J.3 Initial Environmental Examination (IEE).pdf

BUREAU/MISSION/PROJECT

USAID 216 ACRO TEMPLATE VERSION 2, MARCH 2018

INITIAL ENVIRONMENTAL EXAMINATION

PROJECT/ACTIVITY DATA

Project/Activity Name: DO1 - Impunity and Violence Decreased in Targeted Regions

Geographic Location(s) (Country/Region): Mexico Amendment (Yes/No), if Yes indicate # (1, 2...): No Implementation Start/End Date (FY or M/D/Y): FY2020 – FY2024 If Amended, specify New End Date: N/A Solicitation/Contract/Award Number(s): N/A Implementing Partner(s): TBD

Bureau Tracking ID: LAC-IEE-21-15 Tracking ID of Related RCE/IEE (if any): NEW Tracking ID of Other, Related Analyses: N/A

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

USAID/Mexico, GRC Office

Other Affected Operating Unit(s):

Lead BEO Bureau: LAC Funding Account(s) (if available):

Original Funding Amount: $ 100,000,000 USD If Amended, specify funding amount: N/A If Amended, specify new funding total: N/A Prepared by: E Reynosa, USAID/Mexico, PRO Date Prepared: November 30, 2020

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: X Environmental Examination ☐Deferral

Environmental Determination(s): X Categorical Exclusion(s) X Negative ☐Positive ☐Deferred (per 22 CFR 216.3(a)(7)(iv)

IEE Expiration Date (if applicable): N/A Additional Analyses/Reporting Required: None Climate Risks Identified (#): Low __3__ Moderate _____ High _____ Climate Risks Addressed (#): Low __3___ Moderate ____ High _____

THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS

PROJECT/ACTIVITY SUMMARY

This project covers activities that support USAID/Mexico’s CDCS Development Objective 1 (DO1) “Impunity and Violence Reduced in Targeted Sectors.” It encompasses a range of justice, crime and violence, human rights, and transparency initiatives designed to reduce the impunity that enables crime, violence, human rights abuses, and corruption. Activities build upon and expand prior USAID investments in these themes, and will continue to develop the GOM’s capacity to effectively and transparently deliver key justice and security services, and collaborate with civil society and citizens to address priority criminal phenomena. They will do so in accordance with and towards the specific objective of GOM compliance with criminal due process, human rights protections, and good governance obligations principles.

USAID envisions that DO1 activities will support key national institutions, such as the National Mechanism to Project Journalists and Human Rights Defenders; however, most interventions will take place at the sub-national level. State, rather than national authorities, are the first line providers of key services - particularly justice and the protection of citizens. State prosecutors prosecute the vast majority of crimes, including those committed by subsidiary groups of transnational criminal organizations, as well as crimes against journalists and human rights defenders. Key civil society and private sector partners for DO1 activities are generally geographically-focused. Interventions will range from direct technical assistance, to support for inter-institutional coordination, policy development, and greater use of data to make informed operational decisions.

ENVIRONMENTAL DETERMINATIONS

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

(22CFR216).

Per USAID Environmental Procedures, certain classes of actions may qualify for a Categorical Exclusion, pursuant to 22 CFR Section 216.2(c)(1) and (2), for which an Initial Environmental Examination, or an Environmental Assessment is not required. The activities described qualify for a categorical exclusion per 22 CFR 216, see table below.

The Mission Environmental Officer (MEO) and the Activity Manager will oversee the implementation of appropriate environmental guidelines. Reports on these matters will be submitted by the Mission to LAC/BEO in Washington periodically.

Table 1, below, summarizes the environmental determinations applicable to the specific projects/activities:

TABLE 1: ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion Citation (if applicable)

Negative Determination

Positive Determination

Deferral

1 Positive Determinations require preparation of a Scoping Statement and Environmental Assessment.

2 Deferrals must be cleared through an Amendment to this IEE prior to implementation of any deferred activities.

Action Type 1: Provide specialized technical assistance to enhance the organizational capacity of the federal, state, and municipal GOM authorities, civil society organizations, private sector, and other relevant stakeholders to strengthen human rights protections, key justice system processes, evidence-based youth violence prevention programs, and mobilize the private sector to advance evidence-informed policy priorities.

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

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

Action Type 2: Facilitate and strengthen multi-stakeholder coalitions to foster citizen support of more effective oversight institutions, increased access to redress for victims, and increased collaboration between civil society, the private sector, and GOM to promote security, human rights, and justice initiatives.

assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

Action Type 3: Provide technical assistance, training, mentoring and other capacity building to CSOs to increase protective factors for at-risk youth and for women and girls’ victims of gender-based violence, journalists, as well as human rights defenders. This also includes training and capacity building to

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

§216.2(c)(2)(v) Document and

CSOs to strengthen their internal capacities.

information transfers

Action Type 4:

Acquisition of IT infrastructure (software and hardware) for office set up and training

X ☐ ☐

Action Type 5: Support meetings to generate information to monitor access to justice, human rights, and violence prevention trends and results. This also includes violence prevention through investments in early warning systems.

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

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

Action Type 6:

Facilitate linkages among key actors and enable the private sector to implement market-driven solutions and facilitate new partnerships. Most actions would be training, forums, meetings, hiring of experts to create campaigns and strengthening local actors through capacity building actions to improve service provision.

22 CFR 216.2

(c)(2) (i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

and (iii) Analyses, studies, academic or research workshops and meetings;

Action Type 7: Sub-awards used to support training, technical assistance, planning, and studies.

22 CFR 216.2 (c)(2)

(i) (i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

and (iii) Analyses, studies, academic or research workshops and meetings;

CLIMATE RISK MANAGEMENT

In accordance with Executive Order 13677 on Climate-Resilient International Development, as of September 2016, all USAID projects and activities require being managed for climate risks. The Climate Risk Management (CRM) process was undertaken and from this the Mission Environmental Officer/Climate Integration Lead determined that the climate risk is low for those activities within the DO1.

The low climate risk indicates climate change is unlikely to materially impact achievement or sustainability of project or activity outcomes. The climate risks identified for the DO1 pertain to the potential for future scarcity of water for activity participants and the possibility of implementer offices/buildings being impacted by flooding due to heavy rains.

BEO SPECIFIED CONDITIONS OF APPROVAL

No additional conditions of approval are required.

IMPLEMENTATION

In accordance with 22 CFR 216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Sections 3, 4, and 5 of the IEE and any BEO Specified Conditions of Approval.

USAID APPROVAL OF REQUEST FOR CATEGORICAL EXCLUSION

Development Objective Name : DO1 - Impunity and Violence Decreased in Targeted Regions and Development

Bureau Tracking ID: LAC-IEE-21-15

Approval:

Terence A. Miller , Acting USAID/Mexico, Mission Director Date

Clearance:

JTW - 12/07/20

Jeremy Williammee, Acting Deputy Mission Director Date

Clearance: Bret Saalwaechter - 12/07/20

Clearance:

Bret Saalwaechter, GRC Director Date

ERF - Dec 2, 2020 Date

Enrique Reynosa, Mission Environmental Officer/Climate Integration Lead

Corey Hancock, Program Officer, USAID/Mexico Date

Date

Concurrence :

Carlos Hasbun, Acting Regional Environmental Officer

Bethzaida Colon, Acting Bureau Environmental Officer Date

12-7-2020

Cleared by email 12/8/2020

CAH - 12/07/2020

DISTRIBUTION: Mission Project Staff

12/9/2020

INITIAL ENVIRONMENTAL

EXAMINATION

CONTENTS

1.0 PROJECT/ACTIVITY DESCRIPTION 5

1.1 PURPOSE OF the IEE 5

1.2 PROJECT/ACTIVITY OVERVIEW 5

1.3 PROJECT/ACTIVITY DESCRIPTION 5

2.0 BASELINE ENVIRONMENTAL INFORMATION 6

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT,

PHYSICAL, CLIMATE, SOCIAL, Threatened and ENDANGERED species) 6

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER

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

POLICIES, AND REGULATIONS 6

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS

APPROPRIATE) 6

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK 7

4.0 ENVIRONMENTAL DETERMINATIONS 7

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS 7

4.2 CLIMATE RISK MANAGEMENT 7

5.0 CONDITIONS AND MITIGATION MEASURES 8

5.1 CONDITIONS 8

5.2 AGENCY CONDITIONS 9

5.3 MITIGATION MEASURES 10

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION 11

7.0 REVISIONS 12

ATTACHMENTS 12

1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE OF THE IEE

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID intervention described herein and recommend determinations and, as appropriate, conditions, for these activities. bUpon approval, these determinations become affirmed, and specified conditions become mandatory obligations of implementation.

This IEE also documents the results of the Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

This IEE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound 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

Under DO1, USAID/Mexico seeks to reduce impunity and violence - and improve security - in targeted regions over the CDCS period. The approach, as outlined in USAID/Mexico’s newly-approved CDCS concentrates on fewer states (15 rather than the previous 24) and consolidates three democracy and governance-related DOs into one - DO1. USAID/Mexico expects to measurably improve the effectiveness, efficiency, and accountability of justice institutions, strengthen communities’ ability to resolve and mitigate conflict, and increase data-driven oversight by non-governmental institutions. USAID will ensure that the gender dimensions of security are incorporated strategically, including an integrated approach to the causes of, and responses to, gender-based violence across this DO. The Mission will continue to partner with the government and the private sector to develop and refine best practices and take them to scale.

This project encompasses all DO1 activities will include the following three Intermediate Results (IRs) - distinct objectives towards which related interventions will contribute:

IR 1.1: More effective, responsive and accountable government institutions

Delivery of security and justice is a core responsibility of the state, constitutionally obligating the GOM to reduce impunity and violence. Under IR1.1, USAID will build government capacity by supporting increased accountability and effectiveness within the justice sector to prioritize and prosecute serious crimes, including those perpetrated by TCO subsidiaries. USAID will support improved institutional performance to investigate, prosecute, and resolve criminal cases—including violence against women—with a core focus on data-driven decision-making and strengthened inter-institutional collaboration, while fostering more robust human rights protections. USAID will support GOM anti-corruption efforts through assistance to improve transparency, audit, and oversight functions. For example, USAID will work with the GOM to implement traceability systems and ensure data sharing in order to increase transparency and ensure better enforcement of laws and policies, thereby reducing opportunities for criminal involvement in the timber industry. USAID will also strengthen mechanisms for human rights protection, to include environmental defenders. These activities will be predominantly focused at the state level and closely coordinated with the Mexican federal government.

IR 1.2: Communities more effectively resolve and mitigate local conflict

Activities under IR1.2 will strengthen mechanisms for victim redress and closure, including for victims of torture, families of the disappeared, and youth intimate partner violence, while facilitating improved communication between families and local authorities. Effective local interventions to resolve conflict and address low-level crime can yield outsized benefits in perceptions of security and confidence in government, while relieving the burden on overstretched criminal justice institutions, allowing them to focus on high impact crimes. USAID will support local governments to identify, process, and resolve less serious offenses and sources of local tension, helping authorities to intervene before these issues escalate to more serious offenses. These efforts will advance collaborative relationships between citizens and local authorities and engage civil society, government, and the private sector to test innovations and scale up evidence-based violence prevention initiatives.

IR 1.3: Expanded engagement with and oversight by non-governmental institutions

Recognizing the importance of evidence-based decision-making, USAID will expand the use and publication of data to help plan, resource, and ultimately find and fund solutions to critical public policy issues. Non-governmental actors, including civil society organizations, the media, community groups, and the private sector, aspire to advocate and constructively engage government partners for security-focused reforms and allocations of public resources based on data. USAID will leverage private sector investment and influence to advocate for the expansion of evidence-informed approaches to public security, human rights, and justice challenges. USAID will improve the connections between businesses associations, civil society, and academia to foster greater accountability for public institutions, advocacy to expand proven security approaches, and participation in consultative processes. USAID will work with civil society organizations to help them advocate for, and engage with, the GOM to implement a national traceability mechanism that will incentivize the private sector to purchase legal timber.

1.3 PROJECT/ACTIVITY DESCRIPTION

To facilitate environmental analysis, this document has identified primary action types. The action type is not an individual undertaking. Every action type includes elements which may cause similar environmental effects, i.e. Categorical Exclusion and/or Negative Determination with Conditions (NDWC). The action types identified for the DO1 include:

REMARKS: All Technical Assistance and/or Training will take place virtually to the maximum extent during the COVID-19 contingency. When health conditions permit, USAID will re-evaluate the most effective format and delivery of envisioned activities. At this time an Amendment to this IEE will be prepared, if guaranteed.

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

Activity —

1) Provide specialized technical assistance to enhance the organizational capacity of the GOM, CSOs, schools, the private sector, and other relevant stakeholders to deter violence, strengthen human rights protections, and support justice and transparency initiatives in communities. Illustrative actions include expert advisory services on organizational development to improve advocacy and policy dialogue within line ministries to improve security and justice services. Assistance could involve policy development, technical training, data collection and analysis, and performance management systems.

2) Facilitate and strengthen multi-stakeholder coalitions to foster citizen support in holding GOM security and justice sector institutions accountable to citizens. Illustrative actions include organizing forums, graduate programs, mentoring and training in outreach and focus groups. Interventions may also support community-based organizations and networks that facilitate citizens engagement with GOM officials and institutions.

3) Provide training, mentoring, and other capacity building to youth to increase protective factors for at-risk youth, journalists, and human rights defenders. This may include training and capacity development to CSOs to better provide protective services, prevent violence, and increase public support for related interventions. Illustrative actions may promote school-based violence prevention programs, implement evidence-based behavior change methodologies such as communication campaigns. They may also include alternative education and vocational training through mentoring networks and linkages to employment opportunities, expanding access to life skills and other non-formal programs, promoting access to education, counselling, employability and other services for at-risk youth. Assistance may also enable CSOs and journalist associations to equip journalists and human rights defenders with more effective risk-analysis and self-protection measures, including enhanced digital security.

4) Acquisition of IT infrastructure (software and hardware) for office set up and training. For newly-awarded activities, USAID/Mexico anticipates both the prime and sub-partners needing to procure standard, ordinary office equipment, to include laptop and desktop computers, printers, mobile phones, etc.

5) Support meetings to generate information to monitor justice, human rights and violence prevention trends and results. This includes violence prevention interventions and investments in early warning systems. Illustrative actions may include analysis to promote youth involvement in sports music and arts programs, promoting participation in youth councils and parliaments, creating a network of community mentors, piloting new community-based reintegration methodologies. They may also enable improved data collection and analysis of justice and human rights trends, including application to capacity development efforts of partnering GOM institutions.

6) Facilitate linkages among key actors and enable the private sector to implement market-driven solutions and facilitate new partnerships. Illustrative actions may include training, forums, meetings, hiring of experts to create campaigns and strengthen civil society and GOM partners to improve services.

7) Specific actions for sub-awards are not yet known but will fall under sub-action types to support training, technical assistance, planning, and studies.

Will this project/activity involve construction3 as defined by ADS 201 and 303? Yes ☐ No X

2.0 BASELINE ENVIRONMENTAL INFORMATION

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL,

CLIMATE, SOCIAL, THREATENED AND ENDANGERED SPECIES) :

DO1 interventions will focus on technical assistance, capacity building, research, analysis, meetings, and training to enhance the organizational capacity of the GOM, CSOs, schools, the private sector, and other relevant stakeholders to deter impunity, violence, strengthen human rights protections, and support justice and transparency initiatives in communities. This includes work undertaken in partnership with national GOM institutions, as well as in the geographic focus areas of the CDCS. USAID does not anticipate adverse environmental or social impacts for these types of activities with exception to the procurement of office equipment such as computers, printers, projectors, and other equipment. As previously mentioned, although USAID does not anticipate that the provision of computers or other basic equipment will significantly affect the environment, implementing partners and grantees should have a disposition plan in place that includes safe disposal protocols of used equipment to avoid contamination to the surrounding environment, including soil and groundwater. Partners and grantees should dispose of equipment in relevant government approved facilities. No other impacts are anticipated, and no threatened or endangered species will be affected.

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL

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

Disposal of electronic waste will be conducted in accordance with guidelines from the Secretariat de Medio Ambiente y Recursos Naturales (SEMARNAT) or any other relevant government agency in Mexico. SEMARNAT maintains a list of certified disposal companies in Mexico that collect non-hazardous and hazardous wastes, including electronic waste.

Additional information is available on the SEMARNAT website: www.gob.mx/semarnat.

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS

APPROPRIATE)

N/A

3 Construction, as defined by ADS 201 and 303, includes: construction, alteration, or repair (including dredging and excavation) of buildings, structures, or other real property and includes, without limitation, improvements, renovation, alteration and refurbishment. The term includes, without limitation, roads, power plants, buildings, bridges, water treatment facilities, and vertical structures. In the box below, describe any construction planned for this project/activity. Refer to ADS 201maw for required Construction Risk Management procedures.

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

PROJECT/ACTIVITY 1:

TABLE 3A. POTENTIAL IMPACTS – PROJECT/ACTIVITY 4

Project/Activity Potential environmental and social impacts Acquisition of IT infrastructure (software and hardware) for office set up and training

These activities may also involve the procurement of office equipment such as computers, printers, and other equipment. It is not anticipated that the provision of computers or other basic equipment will have a significant effect on the environment. However, at a minimum, the partner/grantee should have a disposition plan in place that includes safe disposal protocols of used equipment to avoid contamination to the surrounding environment, including soil and groundwater.

4.0 ENVIRONMENTAL DETERMINATIONS

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS

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

Specified conditions, detailed in Section 5, become mandatory obligations of implementation, per ADS 204.

TABLE 4: ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion Citation (if applicable)

Negative Determinatio n

Positive Determination

Deferral

Provide specialized technical assistance to enhance the organizational capacity of the GOM, CSOs, schools, the private sector, and other relevant stakeholders to deter violence, strengthen human rights protections, and support justice and transparency initiatives in communities. Illustrative actions include expert advisory services on organizational development to improve advocacy and policy dialogue within line ministries to improve security and justice

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

§216.2(c)(2)(v)

4 Positive Determinations require preparation of a Scoping Statement and Environmental Assessment.

5 Deferrals must be cleared through an Amendment to this IEE prior to implementation of any deferred activities.

services. Assistance could involve policy development, technical training, data collection and analysis, and performance management systems.

Facilitate and strengthen multi-stakeholder coalitions to foster citizen support in holding GOM security and justice sector institutions accountable to citizens.

Illustrative actions include organizing forums, graduate programs, mentoring and training in outreach, focus groups.

They may also support community-based organizations and networks that facilitate citizens engagement with GOM officials and institutions.

assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

Provide training, mentoring, and other capacity building to youth to increase protective factors for at-risk youth, journalists, and human rights defenders. This may include training and capacity development to CSOs to better provide protective services, prevent violence, and increase public support for related interventions.

Illustrative actions may promote school-based violence prevention programs, implement evidence-based behavior change methodologies such as communication campaigns. They may also include alternative

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

§216.2(c)(2)(v) Document and education and vocational training through mentoring networks and linkages to employment opportunities, expanding access to life skills and other non-formal programs, promoting access to education, counselling, employability and other services for at-risk youth. Assistance may also enable CSOs and journalist associations to equip journalists and human rights defenders with more effective risk-analysis and self-protection measures, including enhanced digital security.

Acquisition of IT infrastructure (software and hardware) for office set up and training

X ☐ ☐

Support meetings to generate information to monitor justice, human rights and violence prevention trends and results. This includes violence prevention interventions and investments in early warning systems.

Illustrative actions may include analysis to promote youth involvement in sports music and arts programs, promoting participation in youth councils and parliaments, creating a network of community mentors, piloting new community-based reintegration methodologies. They

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

§216.2(c)(2)(v) Document and may also enable improved data collection and analysis of justice and human rights trends, including application to capacity development efforts of partnering GOM institutions.

Facilitate linkages among key actors and enable the private sector to implement market-driven solutions and facilitate new partnerships.

Illustrative actions may include training, forums, meetings, hiring of experts to create campaigns and strengthen civil society and GOM partners to improve services.

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

§216.2(c)(2)(v)

Specific actions for sub-awards are not yet known but will fall under sub-action types to support training, technical assistance, planning, and studies

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.)

§216.2(c)(2)(v)

4.2 CLIMATE RISK MANAGEMENT

This section summarizes the methodology used and findings of the CRM Screening, in accordance with ADS 201mal. The project design team, in consultation with the CIL, considered the potential effect of climate risks/stressors on the sustainability of the project (changing precipitation patterns, rising temperature, floods, droughts, fires, landslides, etc.) in addition to the impact of project activities on the climate (increased greenhouse gas emissions, land use changes, etc.). See Annex 1 for the complete CRM table.

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 Work Plans 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 (as applicable).

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. 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 (as applicable).

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-award Screening: The A/COR will ensure the IP uses an adequate environmental screening tool to screen any sub-award 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 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. As described in Table 5A, USAID does not anticipate that the provision of IT equipment will have significant adverse environmental impacts. Therefore, an EMMP is not required for any activity that procures IT office equipment. However, at a minimum, the partner/grantee will develop a disposition plan that includes safe disposal protocols of used equipment to avoid contamination.

PROJECT/ACTIVITY 1:

TABLE 5A. SUMMARY OF MITIGATION MEASURES FOR PROJECT/ACTIVITY 4

Project/Activity Mitigation Measure(s) Acquisition of IT infrastructure (software and hardware) for office set up and training

Because it is not anticipated that the provision of computers or other basic equipment will have a significant effect on the environment, an EMMP is not required. However, at a minimum, the partner/grantee will develop a disposition plan that includes safe disposal protocols of used equipment to avoid contamination.

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION

The determinations recommended in this document apply only to activities and sub-activities described herein. .Other 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 projects/activities described herein do not involve actions normally having a significant effect on the environment, including those described in 22 CFR 216.2(d).

In addition, other than projects/activities determined to have a Positive Threshold Determination 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);

● Research, testing, or use of genetically engineered organisms per §216.1(b)(1), ADS

● 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 22 CFR 216.3(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:

Annex 1: Project Climate Risk Management Summary Table

ANNEX 1. PROJECT CLIMATE RISK MANAGEMENT SUMMARY TABLE

Defined or Anticipate d 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

Education, technical assistance, or training programs, analyses, studies, academic or research workshops and meetings, document and information transfer, studies, communicati ons, and outreach, etc.

Heavy rains and floods likely to occur which will make it difficult for personnel to travel due to damaged roads or other infrastructure or makes remote locations inaccessible.

LOW All risks accepted.

During planning specific tasks and site visits will take into account most recent climate information.

N/A Promote early warning systems by

GOM

emergency authorities that can alert local justice systems to take proactive actions before potential crime increase because of natural disasters.

Extreme weather event likely to occur which will make it difficult for personnel to travel due to damaged roads or other infrastructure or makes remote locations inaccessible.

LOW All risks accepted.

During planning specific tasks and site visits will take into account most recent climate information.

N/A

Extreme heat event likely to occur which could adversely affect personnel’s’ health.

LOW All risks accepted.

During planning specific tasks and site visits will take into account most recent climate information.

N/A