J.5_ESSA_-_Request_for_Categorical_Exclusion-RCE.pdf

BUREAU/MISSION/PROJECT

USAID 216 RCE TEMPLATE VERSION 2, APRIL 2018

REQUEST FOR CATEGORICAL

EXCLUSION

ACTIVITY DATA

Activity Name: Education Systems Strengthening Activity Geographic Location(s) (Country/Region): Liberia (nationwide with a focus on Bong, Grand

Bassa, Lofa, Margibi, Montserrado, and Nimba counties)

Amendment (Yes/No), if Yes indicate # (1, 2...): No Implementation Start/End Dates (FY or M/D/Y): FY 2022- 2027 If Amended, specify New End Date: N/A Solicitation/Contract/Award Number: TBD Implementing Partner(s): TBD Bureau Tracking ID: Liberia Education Systems Strengthening Activity https://ecd.usaid.gov/document.php?doc_id=54443 Tracking ID of Related RCE/IEE (if any): N/A Tracking ID of Other, Related Analyses: N/A

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s):

(e.g. Mission or Bureau or Office)

Liberia

Other Affected Operating Unit(s): N/A Lead BEO Bureau: Africa Funding Operating Unit(s):

(e.g. Mission or Bureau or Office)

Liberia

Funding Account(s) (if available):

Original Funding Amount: $23,000,000 If Amended, specify funding amount: N/A If Amended, specify new funding total: N/A Prepared by: Barton Pogue Date Prepared: August 31, 2021

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: X Request for Categorical Exclusion Deferral

Environmental Determination(s): Categorical Exclusion Deferred (per 22CFR216.3(a)(7)(iv))

Categorical Exclusion Expiration Date (if different from implementation end date):

Additional Analyses/Reporting Required:

Climate Risks Identified (#): Low ______ Moderate ______ High ______ Climate Risks Addressed (#): Low ______ Moderate ______ High ______ https://ecd.usaid.gov/document.php?doc_id=54443

USAID 216 RCE TEMPLATE VERSION 2, APRIL 2018

THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS

PROJECT/ACTIVITY SUMMARY

The overall purpose of the Activity is a more capacitated and decentralized Ministry of Education (MOE) that drives, measures, and incentivizes the delivery of quality and inclusive education to keep students in school and improve learning outcomes for all children and youth, especially in early grades and for overage students, students in rural communities, and students with disabilities. In support of this end, the Activity will provide technical assistance services that meet requirements specified by the Agency. Specifically, through a human and institutional capacity development approach that catalyzes decentralization and improves efficiencies, the activity will partner with the MOE and development partners to drive sustainable reform in data collection and analysis, resource management, and accountability.

The majority of current and planned education interventions have received categorical exclusions from further environmental review, including teacher training, general curricula and resources development, standards, testing, student services, community mobilization/advocacy, innovative technologies, institutional capacity building, and program learning and assessment.

Small-scale rehabilitation and construction activities received negative determinations with conditions. The Education Office and its implementing partners actively monitor and evaluate any potential environmental implications of their work. All planned activities, including this Activity, will pursue separate environmental examination clearances.

ENVIRONMENTAL DETERMINATIONS

The nature and scope of the proposed activity are not expected to have any significant adverse impacts on both the natural and physical environment. This activity is thus recommended for Categorical Exclusion per 216.2(C)(2)(i),(iii) and (v). Upon approval of this document, the determination becomes affirmed, per agency regulation.

The actions described justify Categorical Exclusions, pursuant to 22 CFR 216.2(c)(1)(i), 216.2(c)(2)(i),(iii) and (v), for which an Initial Environmental Examination, or an Environmental Assessment are not required because the actions do not have an effect on the natural or physical environment. Upon approval of this document, the determinations become affirmed, per Agency regulations (22CFR216).

TABLE 1: ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion Citation (if applicable) Deferral Education Systems Strengthening Activity

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the

USAID 216 RCE TEMPLATE VERSION 2, APRIL 2018

environment (such as construction of facilities, etc.)

Activity 1: Improve evidence-based decision making

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

Activity 2: Improve resource management

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such

Activity 3: Improve accountability

§216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such

CLIMATE RISK MANAGEMENT

The final rating of the Mission’s Climate Risk Analysis for the education sector was “moderate.”

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

Climate risks to the education sector depend, in part, on climate impacts to other sectors, including agriculture, WASH, and health and nutrition. In Liberia, climate change will exacerbate the root causes of poor school attendance, teacher retention, and learning success. School attendance and learning success may decline if: 1) vector- and water-borne diseases increase due to higher temperature and reduced water quality; and 2) family livelihoods are compromised by extreme events or declining agricultural productivity from variable rainfall and higher temperatures. Families may pull children from school if family incomes decline due to climate impacts. Students may experience impaired cognitive function due to poor health and nutrition.

Extreme weather events, including heavy rains and floods, may negatively impact school attendance and teacher retention.

Opportunities to strengthen climate resilience identified in the climate risk analysis that apply to this activity include school emergency planning that involves students, teachers, parents, and communities, which may be part of larger education management processes in place to monitor and ensure school quality.

BEO SPECIFIED CONDITIONS OF APPROVAL

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

• Ensure all activities addressed by this IEE adhere to current, applicable COVID-19 guidelines. Refer to the AFR COVID-19 PIEE (attached and linked here --

USAID 216 RCE TEMPLATE VERSION 2, APRIL 2018

https://ecd.usaid.gov/document.php?doc_id=52754) for links to U.S. and international guidance on appropriate measures to reduce COVID-19 transmission. Such measures may include, but are not limited to social distancing, use of personal protective equipment, limiting the size of gatherings and travel, and effective disinfection.

• Share with the partner:

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

o Applicable COVID-19 guidance from local authorities;

o The following Agency-wide “COVID-19 GUIDANCE FOR IMPLEMENTING

PARTNERS” page on the USAID website: https://www.usaid.gov/work-usaid/resources-for-partners/covid-19-guidance-implementing-partners.

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

IMPLEMENTATION

In accordance with 22CFR216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Section 3 of this RCE and any BEO Specified Conditions of Approval.

USAID 216 RCE TEMPLATE VERSION 2, APRIL 2018

USAID APPROVAL OF REQUEST FOR CATEGORICAL EXCLUSION

PROJECT/ACTIVITY NAME: Education Systems Strengthening Activity

Bureau Tracking ID: https://ecd.usaid.gov/document.php?doc_id=54443

Approval: Cleared 10/28/2021 James Wright, Mission Director Date

Clearance: Cleared 10/26/2021 Kimberlee Bell, Acting Deputy Mission Director Date

Clearance: Cleared 10/26/2021 Kimberlee Bell, PPD Director Date

Clearance: Cleared 09/14/2021 Kokulo Yorgbor Jr., Mission Environmental Officer Date

Clearance: Cleared 09/11/2021 Anh Pham, Education Office Director Date

Clearance: Cleared 09/01/2021 Barton Pogue, COR Date

Clearance: Cleared 10/14/2021 Ro Wietecha, Regional Legal Officer Date

Clearance: Cleared 10/29/2021 Henry Aryeetey, Regional Environmental Advisor Date

Clearance: Cleared 12/07/2021 Colin Quinn, Climate Integration Lead Date

Concurrence: 12/07/2021 Brian Hirsch, Africa Bureau Environmental Officer Date https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fecd.usaid.gov%2Fdocument.php%3Fdoc_id%3D54443&data=04%7C01%7CCarmen.Saab%40cadmusgroup.com%7C7a169eb7b6d04a1c2a0208d9b9995fa2%7C9775d500e49b49a79e241ada087be6ee%7C0%7C0%7C637744890663169598%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=hSdJ4Z90Svxm2J7voMuoT%2BK4w3VOvW%2FjLgrIqgW%2FjXs%3D&reserved=0

USAID 216 RCE TEMPLATE VERSION 2, APRIL 2018

1.0 PROJECT AND ACTIVITY DESCRIPTION

1.1 PURPOSE AND SCOPE OF RCE

The purpose of this document is to establish that the proposed activities under the Activity belong to classes of actions eligible for Categorical Exclusions as set out in Agency regulations (22CFR 216.2(c)) and that there are no foreseeable significant direct or indirect impacts that would preclude them from receiving a Categorical Exclusion. Upon approval of this document, the Categorical Exclusions are affirmed for the activity. This analysis also documents the results of the activity level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201 mandatory reference 201mal). This RCE is a critical element of a mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation.

1.2 PROJECT OVERVIEW

The overall purpose of the Activity is a more capacitated and decentralized MOE that drives, measures, and incentivizes the delivery of quality and inclusive education to keep students in school and improve learning outcomes for all children and youth, especially in early grades and for overage students, students in rural communities, and students with disabilities. In support of this end, the Activity will provide technical assistance services that meet requirements specified by the Agency. Specifically, through a human and institutional capacity development approach that catalyzes decentralization and improves efficiencies, the activity will partner with the MOE and development partners to drive sustainable reform in data collection and analysis, resource management, and accountability.

1.3 PROJECT DESCRIPTION

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

Education Systems Strengthening Activity Activity 1: Improve evidence-based decision making Sub-activity 1.1: Data on education quality and equity regularly collected Sub-activity 1.2: Data analysis and utilization skills improved Activity 2: Improve resource management Sub-activity 2.1: Innovative mechanisms to finance and incentivize education quality and equity piloted Sub-activity 2.2: Education sector human resource management systems strengthened Activity 3: Improve accountability Sub-activity 3.1: Supervision and monitoring mechanisms strengthened Sub-activity 3.2: Advocacy for education quality and equity expanded

USAID 216 RCE TEMPLATE VERSION 2, APRIL 2018

2.0 ENVIRONMENTAL ANALYSIS

2.1 JUSTIFICATION FOR CATEGORICAL EXCLUSION

The activities under the Education Systems Strengthening Activity are among the classes of actions listed in 22CFR216.2(c)(2) and have no foreseeable significant direct or indirect adverse effect on the environment. Therefore, under 22CFR216.2(c)(1), neither an IEE nor an EA will be required for these activities. Instead, a Categorical Exclusion is recommended for the projects/activities described above in Section 1.3 as follows:

TABLE 3: RECOMMENDED DETERMINATION FOR CATEGORICAL EXCLUSION

Activity: Education Systems Strengthening Activity

Recommended Determination for Categorical Exclusion

All sub-activities §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)(iii) Analyses, studies, academic or research workshops and meetings §216.2(c)(2)(v) Document and information transfers

USAID 216 RCE TEMPLATE VERSION 2, APRIL 2018

2.2 CLIMATE RISK MANAGEMENT

TABLE 4. ACTIVITY 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 activity elements identified through either the strategy- or project-level climate risk assessment.

Risk Rating Low/Moderate/ High

How Risks are Addressed at Activity 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.

Sub-activity 1:

Improve evidence-based decision making

Sub-activity 2:

Improve resource management

Sub-activity 3:

Improve accountability

The climate risks identified under the Climate Risk Management Summary from the Education Project relate to small-scale refurbishment which will not be a part of this Activity.

Low All sub-activities have at their foundation technical assistance and capacity building which will require staff time, production of materials, training, workshops, and meetings. The activity will consider the possible impact of extreme weather such as heat, droughts, and flooding, which could affect implementation.

The activity will plan alternative options for the delivery of technical assistance in the event of such disruption.

The COR will closely monitor whether there are any unforeseen impacts of climate change which may affect the implementation and sustainability of the Activity. If identified, the COR should amend this Request for Categorical Exclusion.

Opportunities to strengthen climate resilience identified in the climate risk analysis that apply to this activity include school emergency planning that involves students, teachers, parents, and communities, which may be part of larger education management processes in place to monitor and ensure school quality.

USAID 216 RCE TEMPLATE VERSION 2, APRIL 2018

TABLE 5. ACTIVITY CLIMATE RISK MANAGEMENT SUMMARY TABLE

Tasks/Defined or Illustrative Interventions

Climate Risks List key risks related to the defined/illustrative interventions identified in the screening and additional assessment.

Risk Rating Low/Moderate/ High

How Risks are Addressed Describe how risks have been addressed in activity design and/or additional steps that will be taken in implementation. If you chose to accept the risk, briefly explain why.

Opportunities to Strengthen Climate Resilience Describe opportunities to achieve multiple development objectives by integrating climate resilience or mitigation measures

Sub-activity 1.1: Data on education quality and equity regularly collected

Sub-activity 1.2: Data analysis and utilization skills improved

Sub-activity 2.1:

Innovative mechanisms to finance and incentivize education quality and equity piloted

Sub-activity 2.2:

Education sector human resource management systems strengthened

Sub-activity 3.1:

Supervision and monitoring mechanisms strengthened

Sub-activity 3.2:

Advocacy for education quality and equity expanded

Reduced effectiveness of Ministry of Education staff, including technical professionals, administrators, and teachers due to disruptions from extreme weather events, including heavy rains, floodings, extreme heat which has a negative impact on education quality and equity.

Low All sub-activities have at their foundation technical assistance and capacity building which will require staff time, production of materials, training, workshops, and meetings. The Activity will consider the possible impact of extreme weather, which could affect implementation, and will plan alternative options for the delivery of technical assistance in the event of such disruption.

The Activity will support planning processes at different levels of the education system, including national, county, district, and school. Considering climate risks and the importance of building resilience should be part of these planning processes and integrated into education management and governance.

USAID 216 RCE TEMPLATE VERSION 2, APRIL 2018

3.0 LIMITATIONS OF THE CATEGORICAL EXCLUSION

The categorical exclusions recommended in this document apply only to the Activity and sub-activities described herein.

Other projects/activities that may arise must be subject to an environmental analysis and the appropriate documentation prepared and approved, whether it be a new Request for Categorical Exclusion, an amendment, or other type of 22CFR216 document.

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).

3.1 MANDATORY INCLUSION OF ENVIRONMENTAL COMPLIANCE REQUIREMENTS IN

SOLICITATIONS, AWARDS, BUDGETS, AND WORK PLANS

USAID will ensure the environmental compliance requirements are incorporated into solicitations, awards, budgets, and work plans, including relevant limitations of Section 3 above.

In addition, climate risk management requirements will also be incorporated.

3.2 GENERAL IMPLEMENTATION & MONITORING REQUIREMENTS (IF APPLICABLE)

USAID will ensure that the following requirements are met:

● Provide briefings for Implementing Partner (IP) on environmental compliance responsibilities

● Ensure integration of compliance responsibilities in prime and sub-awards and grant agreements;

● Ensure compliance with applicable partner country requirements

● Annual review of project activities to ensure that scope is still covered by Categorical Exclusion

ATTACHMENTS

ATTACHMENTS