DCN_2013_GEO_010_REAP.pdf

DCN: 2013-GEO-010

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 1

U.S. Agency for International Development

INITIAL ENVIRONMENTAL EXAMINATION (IEE)

Restoring Efficiency to Agriculture Production USAID/Caucasus

A. BACKGROUND AND ACTIVITY DESCRIPTION

Activity/Project Name: Restoring Efficiency to Agriculture Production (REAP) / Improving Competitiveness and Employment Generation in Georgia Project

Assistance Objective: DO 2, Inclusive and Sustainable Economic Growth

Program Area: IR 2.2. Increase Competitiveness and Employment Generation in Targeted Sectors

Country(ies) and/or Operating Unit: Georgia Originating Office: Office of Economic Growth Date: February 21, 2013 PAD Level IEE: Yes No Supplemental IEE: Yes No RCE/IEE Amendment: Yes No

DCN of Original RCE/IEE:

DCN of Amendment(s):

If Yes, Purpose of Amendment (AMD):

DCN(s) of All Related EA/IEE/RCE/ER(s):

2010-GEO-008; 2011-GEO-016 (AMD2); 2011-GEO-007

(AMD1); 2010-GEO-052 (IEE); 2012-GEO-023 (AMD2);

2011-GEO-015 (AMD1); 2010-GEO-057 (IEE)

Implementation Start/End: 09/30/2013 - 09/30/2018 09/30/2013 - 09/30/2018

Funding Amount: LOP Amount:

AMD Amount: $

Contract/Award Number (if known):

IEE Expiration Date (if any): Reporting due dates (if any):

Recommended Environmental Determination:

Categorical Exclusion: Positive Determination:

Negative Determination: Deferral:

Additional Elements:

Conditions: Local Procurement:

Government to Government: Donor Co-Funded:

Sustainability Analysis: Climate Change Vulnerability Analysis:

B. BACKGROUND AND PROJECT/ACTIVITY OVERVIEW

1. Proposed Federal Action: To enhance the ability of the agriculture sector to stimulate inclusive, sustainable economic growth in Georgia through increased incomes and employment.

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USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 2

2. Project Overview: The REAP Activity is an element of the Improving Competitiveness and Employment Generation in Georgia Project (the Project), which is designed to achieve the results described in USAID/Caucasus’s Country Development Cooperation Strategy (CDCS) under Development Objective (DO) 2, ‘Inclusive and Sustainable Economic Growth,” Intermediate Result (IR) 2.2, “Increased Competitiveness and Employment Generation in Targeted Sectors.” This result will be achieved through three Sub-Intermediate Results (Sub-IR) focused on small- and medium-sized enterprise (SME) growth and development, improving agricultural productivity and market linkages, and increasing access to capital. Activities under the Project will focus on improving the ability of Georgian farms and firms to supply high-quality products in sufficient quantity to respond to the demands of domestic and global markets. These results will be achieved by improving farmers’ access to quality agricultural inputs, mechanization services, and technical advice, working with agribusinesses to improve the management and operations, building capacity at the Ministry of Agriculture (MOA) to provide public services necessary to improve agricultural productivity, and increasing investment in the agriculture sector.

The Project will be composed of at least four new Activities; Restoring Efficiency to Agriculture Productivity (REAP), New Leasing Development Credit Authority Guarantee (DCA), MOA Agriculture Extension and Advisory Services Capacity Building, and MOA Statistical Analysis and Strategic Planning Capacity Building.

The Project is designed at the DO level of the new CDCS, and therefore, it will also include ongoing Activities under DO2, including The Economic Prosperity Initiative (EPI), New Economic Opportunities (NEO) and ongoing DCAs and Annual Program Statement – Georgia (APSG) awards.

The Project will have the flexibility to include future Activities, including a Development Grants Program (DGP), APSG awards, Global Development Alliances (GDAs), and evaluations and assessments related to this DO.

3. Activity Overview: The REAP Activity will make grants and technical assistance (TA) available to existing and newly-formed private enterprises in the agriculture sector, including input suppliers, machinery service providers, storage facilities, sorting/grading centers, and small- and medium-scale processors. Grants and TA may also be provided to primary production businesses, cooperatives, or associations. Grant applicants meeting certain criteria will be provided with TA to develop viable business plans, and selected applicants will receive matching grants and additional TA to implement their business plans. Additional TA will be provided to farmers and non-grantee SMEs to improve technical and business skills and facilitate improved linkages between input suppliers, farmers, value-adding enterprises, and end markets (both domestic and international).

Through these activities, it is expected that REAP will achieve the following objectives:

Sustainably increase the availability and utilization of agricultural inputs, services, and technical information among small-holder and emerging commercial farmers

Improve the business operations, quality, and profitability of beneficiary agribusinesses Increase skills, yields, and incomes of farmers linked to assisted businesses Increase employment opportunities in the agriculture sector

C. COUNTRY AND ENVIRONMENTAL INFORMATION

1. Country Information: Georgia is situated along the Black Sea and borders the neighboring countries of Azerbaijan, Armenia, Turkey, and Russia. The physical terrain of Georgia is mountainous. The population of Georgia is approximately 4.5 million. The capital city is Tbilisi with a population of 1.5 million people. Natural resources include iron ore, hydropower generation, manganese deposits and forestry. The coastal climate is suitable for the growth for tea and citrus fruits. Industries include

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 3 winemaking, steel, textiles, wood products and machinery. The Republic of Georgia is still recovering from one of the worst collapses suffered by any post-communist country. The social system is stressed further by the war with Russia in August 2008 over occupied territories of South Ossetia and Abkhazia.

Areas hardest hit by the current economic situation and influx of internally displaced persons (IDPs) from the Abkhazian conflict in 1992 and the most recent war in August 2008 in South Ossetia have been the regions of Shida Kartli, Imereti and Samegrelo where over 200,000 IDPs currently reside. The resident populations of other parts of Western Georgia, who though not physically displaced, are also victims of the conflict in Abkhazia. They are forced to compete with IDPs for limited economic opportunities, housing, access to land and scarce government assistance. Chronic unemployment remains one of the greatest obstacles to improving living standards. In four years’ time, after the war with Russia, and in the confines of the global economic crises, Georgia’s economy is slowly recovering and in 2013-2015 is projected to return to the pre-war growth of 6-9 percent annually. However, Georgia’s workforce lacks skills and education commensurate with requirements of such rapid growth, and can significantly challenge the country’s economy and further development.

The National Environmental Action Plan (NEAP, 2000) and National Biodiversity Strategy and Action Plan (NBSAP, 2005) are the main national level policy documents related to biodiversity conservation.

Both of these documents are outdated and not used in practice in Georgia. The Ministry of Environment Protection of Georgia began the process of preparing a new NEAP and NBSAP in 2009. Georgia is a party to the major international treaties concerning biodiversity and natural resources. These include:

Convention on Biological Diversity 1994, United Nations Framework Convention on Climate Change 1994, Convention on International Trade in Endangered Species of Wild Fauna and Flora 1996, Convention on Wetlands of International Importance especially as Waterfowl Habitat 1997, Convention on the Conservation of Migratory Species of Wild Animals 2000, Agreement on the Conservation of Bats in Europe 2002, and a number of others. The most relevant to biodiversity conservation include:

Convention on the Conservation of European Wildlife and Natural Habitats (2009), Cartagena Protocol on Biosafety to the Convention on Biological Diversity (2009); and the Protocol to the Convention on the Prevention of Marine Pollution by Dumping of Wastes and other. Compliance with these treaties and agreements is not monitored closely by the Government of Georgia (GOG) or the international community. New activities will refer to these documents during the design process.

Georgia is a small developing economy, with a population of approximately 4.5 million people and a gross national income (GNI) of USD 2,560. According to a 2009 World Bank report, 25% of the population lives below the poverty line, with higher rates in rural areas. However, poverty rates vary greatly among regions. For example, the World Bank report estimates that 59% of the population in the Shida Kartli region lives below the poverty line, while in the neighboring Kvemo Kartli region the rate is only 8%. In any case, nearly half of the population lives in rural areas, where low-intensity, subsistence farming provides the principal source of livelihood, often coupled with social support programs and intra-family assistance. The Gini coefficient for Georgia is 43 (National Statistics Office of Georgia (GeoStat)), which puts the country behind most of its post-Soviet neighbors in terms of income equality. This has been fueled by the “jobless growth” occurring in Georgia, resulting from economic reforms benefitting primarily the elite and a small yet growing middle class, and a focus on investments in sectors such as banking and real estate, which creates few jobs. As USAID is focused on supporting inclusive economic growth, REAP will focus on the agriculture sector to ensure that the rural poor have an opportunity to receive economic benefits from its activities.

Agriculture plays an important role in the Georgian economy and, for many years, was the most significant sector from a gross domestic product (GDP), employment, and export standpoint. However, since the collapse of the Soviet Union and the dismantling of the collective agricultural system, the Georgian agriculture sector has been slow to recover. The privatization of land has resulted in the average household owning approximately 1.25 hectares, which is often spread over multiple non-contiguous plots. Additionally, much of the infrastructure developed under the Soviet system has fallen

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 4 into disrepair without a system in place to fund and manage its maintenance. This includes crucial irrigation and drainage systems, storage facilities, and roads. Consequences of the decline in production include increased food imports, rural unemployment and underemployment, increased rural poverty, and a decline in availability of domestic inputs for food processing industries.

2. Baseline Environmental Information

a. Environmental Context Related to the Project: As Georgia takes the next steps after major accomplishments in reforming legislation and regulations, much of the need for the REAP Activity is for support and TA to SMEs to improve productivity and quality of the agriculture sector.

The REAP Activity will also have a substantial portion of assistance dedicated to issuing grants to SMEs that provide inputs and services to agriculture producers. Grant recipients will be identified during the implementation phase of the project, but it is expected that some of the activities conducted by the sub-grantees could have potential impacts on biodiversity, land, water, air and human health. It is important to conduct an environmental assessment (EA) to evaluate potential activities and to establish procedures to asses and mitigate environmental risks during the implementation of the project. For this and other assistance with potential environmental impacts subject to 22 CFR 216, REAP will have an environmental expert on staff to advise, monitor, and document on technical assistance programs to ensure that environmental protection and mitigation is implemented and evaluated for effectiveness.

The expert will also provide advice on the use of practices that conserve resources, mitigate risks to humans and the environment, and promote greater overall efficiency through improved production techniques and technologies. The expert will also participate in the development of work-plans for education, TA, and training activities to ensure that they incorporate environmental best practices.

Because the REAP Activity will be tasked with increasing the productivity of the Georgian agricultural sector, likely an important part of this process will be the appropriate use of modern pesticides, which protect crops and improve economic yield. Thus, the project will directly or indirectly disseminate information on pesticides used to control weeds, insects, fungi and other pests. It is envisioned that the REAP Activity will provide training on the appropriate storage, transportation, handling, use (including application rates), and disposal of these products.

To accomplish this—and do it well—project technical staff, especially trainers will need to be well-versed in applicable crops, important pests of each crop and specific integrated pest management (IPM) measures used to prevent and treat each pest of each crop. The NEO and EPI Pesticide Evaluation Report and Safe Use and Action Plans (PERSUAP) will be a valuable source of information and guidance in this pursuit (For a summary see Attachment 1: PERSUAP Conditions and Program Management Actions on Compliance). Project technical staff will need to fully understand and use information contained in Annex 1 of the PERSUAP. Annex 1 is a matrix of all Georgian crops, important pests and preventive and curative IPM tools and tactics used as state of the art in other parts of the region and world.

Further, these same project technical staff and trainers will need to understand important characteristics and restrictions of pesticides registered and available in Georgia. This includes potential impacts on human health, environment and natural resources. These are analyzed in Annex 7 and then the non-approved pesticide active ingredients discovered—and that should not be promoted to project beneficiaries, as well as exceptions, are listed in Annex 8 of the PERSUAP.

Moreover, project technical staff and trainers will need to understand best practices for pesticide safety including storage, transportation, handling, use (including application rates), and disposal of pesticides.

These best practices are either detailed or linked to websites in the PERSUAP.

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 5

b. Description of Relevant Environmental and Natural Resources Policy, Law and Regulation: Georgia has a significant number of laws, President’s orders and Government acts on environmental protection.

Some examples include:

The Law on Environmental Protection (1999 and updated) Law on Environmental Impact Permit (1991 and updated) Law on Ecological Expertise (2007) Law on Protected Areas Forestry code (currently being updated) Water law (under the development) Red Book

The Law on Ecological Expertise of 2007 remains the framework for environmental impact assessments (EIAs) that apply to new projects that may have adverse impacts on the environment. EIAs are part of the state ecological expertise (SEE) authority. Citizens and public organizations have access to EIAs and can express their views according to Aarhus and Espo conventions.

In addition to Georgian law, United States Government (USG) environmental policy compliance is required for all new activities.

c. Sustainability Analysis: Sustainability is a fundamental concern for the Project, which aims to contribute to sustainable, inclusive economic growth in Georgia. USAID/Caucasus will incorporate sustainability concerns into the designs of all subsequent activities to ensure that USAID’s investment in the Project continues to benefit Georgian society following its conclusion. Overall, the Project will build capacity in both the public and private sector to strengthen agricultural value chains which will continue to provide both improved incomes and employment after the end of the Project.

Identified stakeholders and beneficiaries of the Project have demonstrated demand for the types of activities, which will be carried out under the Project. Interventions will be carried out in such a way that maximizes local ownership of the activities, such as using existing service providers to conduct trainings.

The Project will develop expertise as part of each planned activity. REAP will create new small and medium enterprises and develop business operations expertise among private sector businesses and agricultural production expertise among farmers.

Recommendations to ensure sustainability of the Project include the following:

As part of any capacity building activity with the GOG undertaken as part of the Project, the implementing partner should be required to work with the relevant GOG entity to develop financial and staff development plans in order to ensure that project results will be sustainable past the Project’s end date.

The Project should assist academic institutions to develop the next generation of agricultural experts that can fill crucial roles in the public and private sector to support agricultural development.

When possible, the Project should facilitate, rather than directly provide, the assistance, by utilizing lead actors (progressive, innovative firms or farms eager to expand their business), existing service providers in the sector, or public sector extension services to ensure the sustainability of activities beyond the completion of the Project and maximize the spread of best practices throughout the sector.

Access to finance is a limiting factor in the ability of farms and SMEs to adopt many new technologies. When possible, the Project should work with financial service providers to

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 6 address issues that have historically limited their ability to provide credit to the agriculture sector through interventions such as crop insurance or land registration.

Provide technically sound recommendations that take into consideration the potential effects of climate change, such as the utilization of water-saving drip irrigation systems or crop rotations.

Where possible within the scope of activities, implementing partners should work with the GOG to address regulatory constraints to agricultural development.

d. Climate Change Vulnerability Analysis: This analysis sought to identify whether and how the Project will affect, or be affected by, medium and longer-term climate change impacts, and how the Project’s design should be adjusted in consideration of climate change vulnerabilities.

In Georgia, the projected increase in temperature and decrease in precipitation, along with the projected increase in the frequency and intensity of natural disasters, will impact the agriculture sector by causing erosion, desertification, and a general degradation of agricultural land; reducing the availability of water; and causing severe damage to crops from high winds, floods, droughts, and other severe weather.

These implications are significant because agriculture is arguably the most economically important sector in Georgia. Some of the resulting recommendations include the following measures:

Reducing land erosion and increasing soil fertility by planting of windbreaks to reduce erosion;

keeping weeds under control and removing stones in pasture; and planting new seed types in degraded areas.

Using gypsum in alkali soils and chemical fertilizers (i.e., nitrogen, sulfur, phosphorus, etc.) in saline soils.

Increasing efficiency and effectiveness of irrigation (if applicable to the project) by using micro-irrigation technologies, such as sprinklers and drip irrigation; using techniques to conserve soil moisture, such as mulching and conservation tillage; investing in drought-tolerant crops; and growing less water-intensive crops.

General policies: promoting crop, income and landscape diversification to reduce the impact of climate change; and increasing water storage to address shortages during droughts or summer months.

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 7

D. EVALUATION OF ACTIVITY WITH RESPECT TO ENVIRONMENTAL IMPACT POTENTIAL AND IDENTIFICATION OF MITIGATION

MEASURES

1. Component One – Grants Program for SMEs in the Agriculture Sector The Implementing Partner will design a competitive grants programs, including detailed selection criteria, focusing on the development or strengthening of agribusinesses, cooperatives or associations providing specific sets or goods or service, which may include, but are not limited to: (1) Farm service centers (FSCs),

(2) Mechanization service centers (MSCs), (3) Storage facilities, (4) Sorting/grading/packing facilities, (5) Consolidation centers, (6) Small-scale processors, (7) Primary agricultural producers (e.g., greenhouse operators, seedling producers), and (8) Service/information providers (e.g., private soil or quality testing laboratories). The implementer will be responsible for establishing appropriate selection criteria for sub-grantees and activities to be supported. Since support to SMEs in the agriculture sector could result in negative environmental impacts, this component will be further analyzed though an EA.

Table 1. Component 1 Illustrative Activities and Potential Environmental Impacts

Illustrative Activities Potential Impacts 22 CFR 216 Environmental Determination

Mitigation Measures/Conditions

1.1 Develop grants manual to support agriculture

sector

Potential impacts of grant-supported activities on land, water, air and human health.

Negative determination with conditions

The Implementing Partner (IP) shall include in the grants manual procedures that eliminate or mitigate environmental impacts.

1.2 Construction of small-scale infrastructure

projects, if defined by sub-grantee’s business plans, including construction of green houses, storage, processing, sorting, packing or other agriculture service facilities.

Potential impacts of infrastructure projects on land, water, air and human health.

Positive Determination

USAID/Caucasus will develop an Environmental Scoping Statement (ESS) that will inform whether project activities need further assessment. For activities that fall under the Positive Determination, an EA will be prepared and approved by the Bureau Environment Officer (BEO). If the ESS determines that activities do not have significant adverse impact, an Environmental Mitigation and Monitoring Plan (EMMP) will be prepared and approved by the Mission Environment Officer (MEO) and BEO.

1.3 Acquisition and transportation of agriculture

equipment, if defined by sub-grantee’s business

Utilization of certain equipment can have potential

Negative determination with conditions

The IP shall develop agricultural equipment selection

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 8 plans, including tractors, processing machinery, refrigeration, maintenance tools, testing equipment, etc.

impacts land, water, air and human health.

and transportation criteria.

Equipment with less impact on environment and human health will be chosen and procured.

These practices shall be captured in one or more EMMPs that must be approved by USAID prior to commencement of the activity.

1.4 Acquisition of agricultural inputs if defined by

sub-grantee’s business plans, including seeds, seedlings, fertilizers, etc.

Utilization of certain inputs can have potential impacts land, water, air and human health. Introduction of new plant varieties, including non-native or potentially invasive species, could affect biodiversity.

Positive Determination

USAID/Caucasus will develop an ESS and an EA if the project will introduce non-native or invasive species in Georgia.

The EA must be approved by the BEO before initiating this activity.

1.5 Planning and implementation of food safety

standards, if defined by sub-grantee’s business plan, including hiring appropriate personnel, drafting plans, testing, establishing internal procedures, installing equipment, etc.

Utilization of certain equipment can have potential impacts land, water, air and human health.

Negative determination with conditions

IP shall develop food safety standards and implementation procedures. These standards and procedures shall be captured in one or more EMMPs that must be approved by USAID prior to commencement of the activity.

1.6 Establish and maintain demo plots to showcase

locally relevant agriculture production, maintenance, harvest and post-harvest techniques and practices.

Utilization of certain inputs, equipment, and harvest/post-harvest techniques can have potential impacts land, water, air and human health.

Positive Determination

USAID/Caucasus will develop an ESS and an EA if the project will introduce non-native or invasive species in Georgia.

The EA must be approved by the BEO before initiating this activity. PERSUAP will be updated as needed and be approved by the BEO.

1.7 Provide trainings to introduce or improve the

capacity to appropriately apply and use agricultural inputs (e.g. seeds, seedlings, and fertilizers) or equipment.

Technical support for certain agricultural activities could entail environmentally impactful activities.

Positive Determination

USAID/Caucasus will develop an ESS and an EA if the project will introduce non-native or invasive species in Georgia.

The EA must be approved by

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 9 the BEO before initiating this activity. USAID/Caucasus will develop update as needed PERSUAP that will be approved by the BEO.

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 10

2. Component Two – Technical Assistance Program The Technical Assistance Program is designed to provide demand-driven TA to grant component beneficiaries to sustainably develop and expand their businesses.

Additionally, the Implementing Partner will develop a system to provide similar demand-driven TA to farmers and non-grant recipient SMEs in the agriculture sector to improve their management and operations. Demand-driven TA will also be provided to facilitate improved linkages between input suppliers, farmers, value-adding enterprises, and end markets (both domestic and international).

Table 2. Component 2 Illustrative Activities and Potential Environmental Impacts

Illustrative Activities Potential Impacts 22 CFR 216 Environmental Determination

Mitigation Measures/Conditions

2.1 Provide technical assistance to SMEs on

strategic planning, business operations, financial plans and/or market assessments.

No adverse impacts are likely

Categorical exclusion pursuant to 216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (e.g., construction of facilities)

N/A

2.2 Train SME operators/managers/owners in

operation and maintenance of equipment and/or facilities

Utilization of certain equipment can have potential impacts land, water, air and human health.

Negative determination with conditions 216.3(a)(2)(iii)

IP shall develop an equipment maintenance manual and provide trainings to SME operators, managers, and/or owners. These practices shall be captured in one or more EMMPs that must be approved by USAID prior to commencement of the activity.

2.3 Provide technical training to farmers on

production, harvesting and post-harvest techniques and practices

Production, harvesting and post-harvest techniques and practices can have potential impacts land, water, air and human health.

Positive Determination

USAID/Caucasus will develop an ESS and an EA if the project will introduce non-native or invasive species in Georgia. The EA must be approved by the BEO before initiating this activity.

USAID/Caucasus will develop update as needed PERSUAP that will be approved by the

BEO.

2.4 Assist with developing business relationships

and addressing requirements of financial No adverse impacts are likely

Categorical exclusion pursuant to 216.2(c)(2)(i) Education, technical

N/A

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 11 institutions to obtain capital for further growth or expansion assistance, or training programs except to the extent such programs include activities directly affecting the environment (e.g., construction of facilities)

2.5 Provide technical assistance to improve target

SME’s transportation, storage, packaging and handling practices.

Transportation, storage, packaging and handling practices can have potential impacts land, water, air and human health.

Positive Determination

USAID/Caucasus will develop an ESS and an EA if the project will introduce non-native or invasive species in Georgia. The EA must be approved by the BEO before initiating this activity.

2.6 Facilitate communication of partner SMEs and

farmers with other farmers and key stakeholders to successfully build linkages.

No adverse impacts are likely

Categorical exclusion pursuant to 216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (e.g., construction of facilities)

N/A

2.7 Assist farming or business associations to

identify policy issues affecting their members’ operations or business performance or to lobby on their behalf.

No adverse impacts are likely

Categorical exclusion pursuant to 216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (e.g., construction of facilities)

N/A

2.8 Collaborate with agricultural specialists to

develop training programs to be provided to clients of grant recipients

Agricultural practices can have potential impacts land, water, air and human health.

Positive Determination

USAID/Caucasus will develop an ESS and an EA if the project will introduce non-native or invasive species in Georgia. The EA must be approved by the BEO before initiating this activity.

USAID/Caucasus will develop update as needed PERSUAP that will be approved by the

BEO.

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 12

2.9 Facilitate relationships between value-adding

agribusinesses and small-holder/emerging commercial farmers

No adverse impacts are likely

Categorical exclusion pursuant to 216.2(c)(2)(i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (e.g., construction of facilities)

N/A

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 13

D. RECOMMENDED ENVIRONMENTAL ACTION

1. Recommended Environmental Determinations:

Categorical Exclusions:

A categorical exclusion pursuant to 216.2(c)(2)(i) for education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (e.g.

construction of facilities and pesticide use) is recommended for activities 1.7, 2.1, 2.2, 2.3, 2.4, 2.5, 2.6, 2.7, 2.8 and 2.9 from Section D.

Per 22 CFR 216.2(c)(1), neither an IEE nor an EA is required for activities which are determined to fall within one or more of the classes of activities listed in 22 CFR 216.2(c)(2), except to the extent that they include specific activities making them subject to a Negative Determination with Conditions or Positive Determination.

Negative Determination with Conditions:

Under §216.3(a)(2)(iii), a negative determination with conditions is recommended for activities 1.1, 1.3, 1.5, and 2.2 from Section D. Specific terms and conditions are presented below in Section E.2.

Positive Determination:

A positive determination is recommended for the following activities 1.2, 1.4, 1.6, 1.7, 2.3, 2.5, and 2.8 under§216.2 (d)(1) (including potentially irrigation or water management projects, agricultural land leveling; drainage projects; large scale agricultural mechanization; new lands development; penetration road building or road improvement projects); §216.3(b) Pesticides; §216.5 for endangered species; and FAA 119 for threats to biodiversity. Specific terms and conditions are presented below in Section E.2.

2. Conditions and Mitigation Measures

a. For activity 1.1, the IP shall include in grants manuals procedures that at a minimum:

i. Reliably identify grant applications or grant-making decisions that may involve support for environmentally sensitive activities and/or activities that require environmental review, licensing or permits under host country environmental regulations

ii. Exclude activities listed in “Limitations” (See Section G.) from grant-making activities

iii. Require verification that such reviews are approved and/or permits or licenses are in place prior to grant issuance

iv. Require verification that prospective grant recipients are aware of their compliance obligations and have adequate capacity and resources to implement them

v. Verify adequacy and effectiveness of environment, health, and safety aspects of the grant-making procedures. If it is determined that this entity has deficiencies in their procedures or in implementation of them, then USAID shall be committed to providing appropriate training and other capacity building; for instance, providing training to acquaint grant-making officers with standard practices followed by major donors in the areas of environmental screening, impact analysis, and promotion of environmentally sustainable projects.

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 14

b. Prior to initiating activities 1.3, 1.5, and 2.2 the IP shall prepare EMMPs in the format provided in the Attachment 2 of this IEE. The Contracting Officer’s Representative (COR) and MEO shall approve the EMMP(s) prior to implementation.

i.EMMPs shall be captured in annual work plans, and therefore budgeted for and reviewed for adequacy at least annually.

ii.Changes in activities, and their associated EMMPs shall necessitate amending the IEE or issuing a Memo to the File (depending on extent and potential impact of the changes)

c. An ESS for all project components that are not subject to categorical exclusion or negative determination with conditions per this IEE shall be prepared per 22 CFR 216.3(4) and approved by the BEO. The scoping process shall be initiated at project inception and encompass stakeholder analysis, project needs assessment and community stakeholder engagement. It shall identify environmental impacts to be considered by sector or type of activity to be considered in the EA and eliminate from further consideration impacts that will not be evaluated.

d. During the environmental scoping process, activities to be undertaken through this project that are found to have no adverse effects on the environment and which are not linked to activities that are associated with effects on the environment, may be excluded from further consideration in the EA.

These activities may proceed with BEO approval of the ESS.

e. An EA per 22 CFR 216.6, shall be prepared based on the SS and cleared by the BEO prior to the start of activities that have not been excluded from further review.

f. The EA shall include baseline environmental information to serve as the basis for future monitoring, an analysis of alternatives to the proposed action for each type of activity and a comparison of environmental effects associated with each alternatives. The baseline environmental information shall include requirements of national and local laws and local permitting requirements for the activities.

g. If during the ESS or EA process, some activities are found to have minimal environmental impacts, which are easily mitigated, with the approval of the BEO, these can be addressed by an abbreviated environmental impact assessment and associated EMMPs. These EMMPs shall be subject to BEO approval and this IEE shall be amended or a new IEE drafted to add the new EMMP requirements.

h. EMMPs based on the findings of the ESS or EA process shall be developed to address potential environmental impacts.

i. The implementers shall be responsible for ensuring site-specific activities are implemented consistent with EMMPs. After the implementer has finalized its activities at a specific site, a signed Record of Compliance with the EMMP (see Attachment 3) shall be submitted to the COR certifying that the organization met all applicable EMMP conditions, a copy shall be provided to the MEO and BEO.

j. If REAP is involved in assistance for procurement or use or both of pesticides not included in the NEO or EPI PERSUAPs (DCN: 2011-GEO-015 and 2011-GEO-016), for example, will be assisting with crops that are not addressed in PERSUAPs of these two projects, then a new or revised PERSUAP will be required for REAP.

3. Monitoring and Reporting

USAID/Caucasus will closely monitor the work of each implementer to assure environmental concerns are addressed from the design through the completion of construction works/activities. This will be assured through USAID approval of activity designs, review of the IP’s environmental reports and

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 15 assessments, and site visits to insure that mitigating actions are implemented. The COR will closely monitor implementation of all activities to ensure compliance with this IEE. Deviations from the requirements set forth in this document should be reported to the MEO to initiate corrective action.

Deviations will be reported to the BEO. Monitoring and reporting responsibilities are divided as follows:

a. The COR, with the support of the MEO, is responsible for monitoring compliance of activities by means of field inspections and reviews of records and scheduling any corrective actions.

b. If at any time the activity is found to be out of compliance with the IEE, the COR shall immediately notify the MEO who in turn shall notify the BEO.

c. Implementing partners shall report on environmental compliance requirements as part of their routine activity reporting to USAID.

d. A summary report of Mission’s compliance relative to this IEE shall be sent to the BEO on an annual basis, normally in connection with preparation of the Mission’s annual environmental compliance report required pursuant to ADS 203.3.8.5 and 204.3.3.

e. The BEO or his/her designated representative may conduct site visits or request additional information for compliance monitoring purposes to ensure compliance with this IEE, as necessary.

f. If at any time the activity is found to be out of compliance with the IEE, the COR shall immediately notify the MEO who in turn shall notify the BEO.

F. MANDATORY INCLUSION OF ENVIRONMENTAL COMPLIANCE REQUIREMENTS IN

SOLICITATIONS, AWARDS, BUDGETS, AND WORKPLANS

Appropriate environmental compliance language shall be included in solicitations and awards (this includes the listed “limitations” for categorical exclusions) for this activity with an appropriate level of funding and staffing to satisfy the environmental compliance requirements set forth in this IEE. Environmental mitigation and monitoring requirements shall also be included in those solicitations and awards.

Solicitations shall include an activity description with task(s) for meeting environmental compliance requirements and appropriate evaluation criteria.

The Implementer will incorporate conditions set forth in this IEE into their work plans.

G. LIMITATIONS OF THE IEE: This IEE does not cover the following activities and therefore should changes in scope implicate any of these issues/activities, a BEO-approved amendment shall be required:

Activities normally having a significant effect on the environment under §216.2(d)(1) [See http://www.usaid.gov/our_work/environment/compliance/regulations.html] except those to be included in the forthcoming ESS and EA;

Support project preparation, project feasibility studies, engineering design for activities listed in §216.2(d)(1), except those to be included in the forthcoming ESS and EA;

Affect endangered species;

Result in wetland or biodiversity degradation or loss;

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 16

Support extractive industries (e.g. mining and quarrying);

Promote timber harvesting;

Provide support for regulatory permitting;

Result in privatization of industrial or infrastructure facilities;

Lead to new construction of buildings or other structures;

Procure or use genetically modified organisms.

H. REVISIONS:

Under §216.3(a)(9), if new information becomes available that indicates that activities covered by the IEE might be considered major and their effect significant, or if additional activities are proposed that might be considered major and their adverse effect significant, this environmental threshold decision will be reviewed and, if necessary, revised by the Mission with concurrence by the BEO. It is the responsibility of the USAID COR to keep the MEO and BEO informed of any new information or changes in the activity that might require revision of this IEE.

I. USAID APPROVAL OF ENVIRONMENTAL ACTION(S) RECOMMENDED

Jesse Gutierrez (drafter/originator) Date

Douglas Balko, Office Director, EG Date

Nick Higgins, Program Officer Date

Peter Young, Regional Legal Advisor Date

Mariam Ubilava, Mission Environmental Officer Date

Roy Plucknett, Deputy Mission Director Date

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Approval:

Stephen M. Haykin, Mission Director Date

Concurrence:

William Gibson, Acting E&E Bureau Environmental Officer Date E&E Bureau Environmental Officer

Distribution:

IEE File Mission Environmental Officer COR File

USAID/Caucasus – Restoring Efficiency to Agriculture Production (REAP) 18

Attachment 1: PERSUAP Conditions and Program Management Actions on Compliance

PERSUAP Conditions Perform IPM and Safe Pesticide Use training (on two or more occasions to ensure that training sticks) for all Georgia assistance activity implementers and beneficiaries that use or procure pesticides with project assistance (see Annex 10).

Subsidize recommended PPE for all Georgia assistance activity implementers and beneficiaries that use or procure pesticides with project assistance (see PPE websites referred and linked to herein).

Activities ensure that implementers and beneficiaries do not procure or use certain pesticides containing the Active Ingredients in Annex 8 with USAID assistance; perform EDD (Environmental Due Diligence) and provide training and recommendations for avoiding any use of such pesticides; perform EDD and require that assisted enterprises show progress to complying with Republic of Georgia law as a condition for receiving project assistance other than training.

Activities use lists of pesticides analyzed herein to match pesticide commercial product names with each of the Active Ingredients found in Annex 8; make a list for Annex 8 and distribute this list to each Republic of Georgia assistance projects implementer.

Ensure that each activity implementer has a copy of the list of pesticides currently registered and available for use, and recommended for future use if registered in Republic of Georgia (these are all listed in Annex 1 with both Active Ingredient (AI) and product names and Annex 7 with pesticide AI names only) and understands their use.

Activities make efforts to obtain, as available, copies of the Material Safety Data Sheets (MSDS) for each of the pesticide products used by beneficiaries on Republic of Georgia assistance projects. See MSDS at:

http://www.bayercropscience.com.au/resources/uploads/msds/file7219.pdf.

Translate into a local language the most critical PERSUAP sections and Annexes for a more efficient use of PERSUAP findings.

Activities work with the Georgian MOA to make provisional PMPs for each applicable crop (use Annexes 1, 2 and 3 as well as local farmer knowledge) so managers and farmers have a tool to predict, prevent and manage pests throughout the season (see PMP examples at http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html, website upper left “Year-Round IPM Programs”).

Activity implementers do hands-on and work shop training that encourages activity-assisted farmers to use PPE, pesticide safety best practices and apply pesticides only during the appropriate times of day (early morning/late afternoon, low wind, no rain).

Once Georgia begins to register pesticides anew, assistance activities check the list of registered pesticides every 6 months to obtain new pesticide registrations & regulatory changes.

As Georgia registers them, or they become available, and when the use of pesticides is required to achieve activity goals, Republic of Georgia assistance activity implementers promote commercially-available pesticides containing natural chemicals listed in Annexes 4 and 5.

For all demonstrations, activity implementers introduce pesticide record-keeping concepts and tools following GlobalGAP or other internationally-accepted BMP procedures.

Program Management Actions on Compliance Activities monitor beneficiary farmers for their understanding and use of best practices found in the field form in Annex 11.

Activities report on monitoring in Annual Reports to USAID COR and MEO, under a heading titled “Environmental Mitigation and Monitoring”.

Activity implementers report on any changes in Republic of Georgia pesticide regulations and registrations.

Annually participate in the amending of this PERSUAP to contain new IPM tactics and any new pesticides registered or available.

Activities write the names of pesticides that cannot be used with USAID assistance into any future grant or sub-contract.

Activity environmental staff members include relevant actions drawn from this SUAP in EMMPs or draft an EMMP containing pesticide issues identified in the SUAP, with ways to mitigate the most common risks.

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Attachment 2: Environmental Mitigation and Monitoring Plan (EMMP) for [provide name of activity] under DCN: [provide DCN of IEE/EA] [Several activity-specific examples are available from the BEU]

Activity Identified

Environmental Aspects or Impacts

Mitigation Measure(s)

Monitoring Indicator(s) Monitoring and

Reporting Frequency

Party(ies) Responsible

Planning and Design (if applicable)

Mobilization (if applicable)

Sourcing of Materials & Equipment (if applicable)

Rehabilitation works (if applicable)

Construction Demobilization (if applicable)

Testing, Operation, and Maintenance (if applicable)

Prepared by:____________________________________________________ Date:________________________________

Cleared by:____________________________________________________ Date:________________________________

Approved by:____________________________________________________ Date:________________________________

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Attachment 3: Record of Compliance with Environmental Mitigation and Monitoring Plans (EMMPs) [Template]

Subject: [Site Name/Primary Project Name/IEE DCN Number] To: [Name], COR/AOR/Activity Manager Copy: [Name], Mission Environmental Office Date:

The [name of the implementing organization] has finalized its activities at the [site name/activity number] to [describe activities that were undertaken]. This memorandum is to certify that our organization has met all conditions of the EMMP for this site activity. A summary of the how mitigation and monitoring requirements were met is provided below.

1. Mobilization and Site Preparation

2. Site Activity Implementation Phase

3. Site Closure Phase

4. Site Activity Handover

Sincerely, [Name], Chief of Party [Name of Implementing Partner Organization]

Approved:

[Name], AOR/COR/Activity Manager

Date

Copy to:

MEO

Bureau Environmental Officer