J.4 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: Promoting Open Business and Integrity (POBI) Activity 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 – FY2025 If Amended, specify New End Date: N/A Solicitation/Contract/Award Number(s): N/A Implementing Partner(s): TBD

Bureau Tracking ID: LAC-IEE-21-22 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: $15,000,000 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: December 22, 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 _____ about:blank about:blank about:blank about:blank

THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS

PROJECT/ACTIVITY SUMMARY

Corruption and the lack of an open business environment (characterized by fairness, integrity and transparency) are issues that affect government, citizens, and the private sector alike. In addition to weakening democratic norms and citizen trust in government, corruption also undermines direct foreign investment and commercial linkages and undercuts the financial and business environments, which is critical to countries’ long-term economic growth and self-reliance. While the United States is Mexico’s main trading partner - accounting for 80 percent of Mexico’s exports and 46 percent of its imports significant barriers exist for U.S. and other market-oriented companies seeking to do business and invest in Mexico, including complicated regulations, opaque business practices, and continually high levels of corruption. In fact, corruption continues to be one of the main obstacles to doing businesses in Mexico, presenting costs and risks for companies of all sizes. The pervasive lack of transparency in public procurement and contracting also creates openings for less discerning foreign competitors that are willing to overlook these issues and are not held accountable to the same integrity standards as U.S. companies.

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 Determination1

Deferra l2

Action Type 1: Provide specialized technical assistance to enhance the capacity of the GOM to combat business sector-related corruption, ensure public sector integrity, support transparency measures, and ensure a fair and competitive business environment, as required under Mexico’s USMCA commitment

§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 partner with the private sector to strengthen integrity practices in line with Mexico’s USMCA commitments and expand engagement on initiatives in support of transparency and open business

§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.)

Action Type 3: Provide technical assistance, training, mentoring and other capacity building to strengthen CSOs to understand and engage in open business initiatives and ensure oversight of critical investments in their communities using audit and open governance tools

§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.)

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.

to foster accountability in the use of public resources.

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

Action Type 4: Acquisition of IT infrastructure (software and hardware) for office set up and training

X ☐

Action Type 5: Sub-awards used to support training, technical assistance, planning, and studies.

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.

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 POBI Activity.

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 POBI Activity 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.

INITIAL ENVIRONMENTAL

EXAMINATION

CONTENTS

1.0 PROJECT/ACTIVITY DESCRIPTION 7

1.1 PURPOSE OF THE IEE 7

1.2 PROJECT/ACTIVITY OVERVIEW 7

1.3 PROJECT/ACTIVITY DESCRIPTION 7

2.0 BASELINE ENVIRONMENTAL INFORMATION 8

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT,

PHYSICAL, CLIMATE, SOCIAL, THREATENED and ENDANGERED SPECIES) : 8

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER

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

POLICIES, AND REGULATIONS 8

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS

APPROPRIATE) 9

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK 9

4.0 ENVIRONMENTAL DETERMINATIONS 9

4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS 9

4.2 CLIMATE RISK MANAGEMENT 11

5.0 CONDITIONS AND MITIGATION MEASURES 11

5.1 CONDITIONS 11

5.2 AGENCY CONDITIONS 12

5.3 MITIGATION MEASURES 13

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION 13

7.0 REVISIONS 14

ATTACHMENTS: 14

Annex 1. Project Climate Risk Management Summary Table 15

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. Upon approval, these determinations become affirmed, and specified conditions become mandatory obligations of implementation. This IEE also documents the results of the Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

This 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

The purpose of this Activity is to strengthen Mexico’s business and investment environment through improved governance and business practices, increased citizen engagement and enhanced coalitions that drive transparency and integrity and promote open business. The high-level expected outcome for this activity is an improved open, transparent, competitive, and accountable business/investment environment in Mexico at both the federal and state levels. Achievement of this outcome will in turn allow Mexico to meet its commitments under the USMCA to ensure greater oversight, transparency and integrity in the business sector and in public procurement, preventing corruption in international trade and investment, and enhancing opportunities for SMEs.

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 POBI Activity 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 capacity of the GOM to combat business sector-related corruption, ensure public sector integrity, support transparency measures, and ensure a fair and competitive business environment, as required under Mexico’s USMCA commitment.

2) Facilitate and partner with the private sector to strengthen integrity practices in line with Mexico’s USMCA commitments and expand engagement on initiatives in support of transparency and open business.

3) Provide technical assistance, training, mentoring and other capacity building to strengthen CSOs to understand and engage in open business initiatives and ensure oversight of critical investments in about:blank their communities using audit and open governance tools to foster accountability in the use of public resources.

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

5) 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) :

Interventions that will be implemented are focused on technical assistance, capacity building, research, analyses, meetings, and training. Adverse environmental impacts are not anticipated for these types of activities with exception to the procurement of office equipment such as computers, printers, projectors, and other standard-issue office equipment. While it is not anticipated that the provision of computers or other basic equipment will have a significant effect on the environment, 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. The partner/grantee should dispose of equipment in the relevant government approved facilities. No other impacts are anticipated, and no threatened or endangered species will be affected.

USAID’s geographic focus is on a limited set of states that are best positioned to use and build on USAID assistance, and ultimately share their experience with other states and municipalities. A key lesson learned from the previous strategy was that after spreading resources across nearly every state to help them meet the minimum competencies of the reform of the criminal justice system, USAID now needs to robustly engage in those states that demonstrate the political will, technical capacity, and financial commitment (from government and private sector) to best absorb and build upon assistance and deliver impact at scale.

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

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.

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS

APPROPRIATE)

N/A

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK

Potential environmental risks for are described in Table 3A. In addition, no adverse impact to the environment is expected for sub-awards as they are all expected to be training, technical assistance, training, planning, and studies, thus meet the Cat Exclusion per §216.2(c)(2)(i). USAID will ensure that the IPs verifies that sub-awards meet this Cat Exclusion. If not, this IEE will be amended, and subsequently the IP will prepare an Environmental Monitoring and Mitigation Plan (EMMP).

PROJECT/ACTIVITY 4:

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 Determination

Positive Determination4

Deferral5

Provide specialized technical assistance to enhance the capacity of the GOM to combat business sector-related corruption, ensure public sector integrity, support transparency measures, and

§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

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.

ensure a fair and competitive business environment, as required under Mexico’s USMCA commitment.

construction of facilities, etc.)

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

Facilitate and partner with the private sector to strengthen integrity practices in line with Mexico’s USMCA commitments and expand engagement on initiatives in support of transparency and open business.

§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.)

Provide technical assistance, training, mentoring and other capacity building to strengthen CSOs to understand and engage in open business initiatives and ensure oversight of critical investments in their communities using audit and open governance tools to foster accountability in the use of public resources.

§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

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

X ☐ ☐

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) Document and information transfers

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, it is not anticipated that the provision of IT equipment will have significant adverse environmental impacts. Therefore, an EMMP is not required for this activity. 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, in lieu of an EMMP and 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 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 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 211

● 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 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

Education, technical assistance, or training programs, analyses, studies, academic or research workshops and meetings, document and information transfer, studies, communicatio ns, 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