J.5_Environmental_Compliand_(IEE)_for_Health.pdf

DCN: Asia 12-213

ENVIRONMENTAL COMPLIANCE FACESHEET FOR THE

INITIAL ENVIRONMENTAL EXAMINATION (IEE)

Objective: Objective 3/ Investing in People

Program Areas: 3.1 Health

Program Elements: 3.1.1 HIV, 3.1.2 Tuberculosis, 3.1.5 Other Public Health

Threats, 3.1.6 Maternal and Child Health, 3.1.7 Family Planning and Reproductive Health

Country/Region: Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, and

Uzbekistan

Funding Period: FY2012 – FY2016

Resource Levels/Amount(s): Estimated $94 million

Statement Prepared by: Jesse Joseph, Health Officer, Health and Education

Office, USAID/CAR Date: September 15, 2012

IEE Amendment? Yes No

Environmental Media and/or Human Health Potentially Impacted (check all that apply):

None Air Water Land Biodiversity Human health Other

Environmental Action(s) Recommended (check all that apply):

Categorical Exclusion(s) Initial Environmental Examination:

Negative Determination: no significant adverse effects expected regarding the proposed activities, which are well defined over life of activity. IEE prepared:

With conditions: no special mitigation measures needed; normal good practices will be used. For the possible limited procurement of equipment, the proposed action is that the implementer is required to ensure that equipment, commodities (also see ADS 312) and materials are procured from certified retailers; environmental safety and quality certificates conforming with national and/or international standards are available; equipment and materials are used in an environmentally sound and safe manner, properly disposed of when applicable at the end of their useful life in a manner consistent with best management practices according to

USG, European Union or equivalent standards acceptable to USAID (see Facesheet Table 2 and IEE Section 4).

With conditions (special mitigation measures specified to prevent unintended impact for activities listed in Facesheet Table 2 and IEE Section 4).

Summary of Findings:

The purpose of this document is to review current and planned activities covered under Objective 3: Investing in People (program elements 3.1.1 HIV, 3.1.2 Tuberculosis, 3.1.5 Other Public Health Threats, 3.1.6 Maternal and Child Health, 3.1.7 Family Planning and Reproductive Health) in the period 2012-2016 by the Health Offices of USAID /CAR and USAID/Kyrgyzstan. Until now, on-going programs have been covered by the umbrella Amendment #2 to the Initial Environmental Examination (IEE) “DCN: 2007- CAR-003”, signed by Bureau Environmental officer (BEO) on 9/3/2002 and valid through September 30, 2012; Phase IEE (DCN: 2008-Taj-001) signed on 7/11/2008 and expired on September 9/30/2010; and MCH and Tajikistan Safe Drinking Water Project (DCN: Asia 09-157), signed by BEO on 30/09/09 which expire on 9/30/2012. This new IEE fully supersedes the existing IEE Amendment #2 for all health activities from 2012 to 2016 and reflects changes in budget, activities, and length of projects.

The following current and planned projects, and illustrative activities, are to be implemented with health funding during FY2012 - FY2016, under the USAID/CAR Program Area 3.1, Health (Table 1).

Table 1. General Activities in the Health Portfolio

Objective 3: Investing in People Program Area: 3.1 Health

Program Element

On-going and planned projects under the Program Element.

Types of Activities

3.1.1, 3.1.2, 3.1.5, 3.1.6, 3.1.7

Quality Health Care Project Abt. Associates

LOP: 09/2010 – 09/2015

LOP Budget: $72,000,000 Countries: Kz, Kg, Tj, Tx, Uz;

The Quality Health Care Project aims to improve health outcomes by providing trainings and technical assistance focused on HIV/AIDS, tuberculosis, family planning and reproductive health, and maternal and child health to Ministries of Health, NGOs and CSOs.

The project has small construction/ renovation activities of health care facilities and procurement of office and laboratory equipment such as Xpert MTB/RIF, a cartridge-based, automated diagnostic test.

3.1.1, 3.1.2

Dialogue on HIV and TB

PSI

LOP: 09/30/2009-09/29/2014

LOP Budget: $22,000,000 Countries: Kz, Kg, Tj, Tx, Uz

The Dialogue on HIV and TB project provides technical assistance, trainings and direct outreach services to increase access to quality HIV prevention and TB prevention and treatment services for most-at-risk-populations. Activities may include small construction activities and procurement of laboratory equipment.

3.1.5 WHO Polio Grant The WHO Polio Grant provides technical assistance for

WHO

LOP: 2010-2013

LOP Budget: $475,000 Countries: Kz, Tj, Uz polio immunization campaigns and improved country surveillance for potential communicable diseases, through trainings and workshops.

3.1.2 WHO PIO Grant

WHO

LOP: 2012-2015

LOP Budget: $3,500,000 Countries: Tx, Uz

The WHO PIO Grant will support technical assistance and trainings to the Uzbek and Turkmen national responses to tuberculosis. Its objectives are to:

1.Strengthen National TB Control Program management, coordination, monitoring and evaluation

2. Strengthen the quality of implementation of Stop TB Strategy plus nationwide.

3.1.6 MCH, FP/RH APS

1. Kazakhstan Association on Sexual and Reproductive Health/

2. Women's League of Creative Initiatives

LOP: 2012 – 2014

LOP Budget: $100,000 ($50,000 each) Countries: Kz

1. Increase access to family planning services and accurate information for families and youth, and upgraded skills and access to evidence-based practices for providers through regional education centers

2. To improve nutrition and feeding for institutionalized children under four years of age in Kazakhstan.

3.1.1 Youth Center (JSI, Inc)

LOP: 2009-2012

LOP Budget: $450,000 Country: Tx

The goal of this project is to reduce the initiation of young people into behaviors which can lead to crime, drug use, poor health, and HIV infection by supporting two youth centers and one drop-in center which provide vulnerable youth with health education and referrals to medical services.

Note: Kg - Kyrgyzstan, Tj -Tajikistan, Tx –Turkmenistan, Kz- Kazakhstan, Uz – Uzbekistan

It is anticipated that in various projects the following activities may take place:

procurement of electric and electronic equipment including computers, electronic devices; small-scale construction or minor renovation activities related to sanitation and hygiene and drinking water supply. All of these activities will require monitoring and screening and application of various mitigation measures as described in IEE Table 2 (IEE Section 4).

Table 2 presents results of environmental screening and recommends threshold determinations for the main types of activities under all program elements.

Table 2. Proposed Health Activities, Recommended Threshold Decisions and required Reg.216 actions

No. Activities Effect on

Natural or Physical Environment

Threshold Decisions and required Reg. 216 actions

1 2 3 4

All Program activities expected to have no effect on the natural or physical environment This includes: education, technical assistance, training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.); consultations, participant training, document transfers and information dissemination, analysis, studies, conferences workshops, study tours, curriculum development, working with training programs, developing information networks

No effect Categorical Exclusion, no actions required.

While these activities are considered to have no impact on the environment, environmental health and quality considerations should be incorporated into all relevant steps along the healthcare continuum, as part of quality assurance and infection prevention approaches.

See IEE Tables 1 and 2 for more details.

II All activities regarding which no significant adverse effects are expected

No special mitigation measures are needed; activities are implemented with conditions that normal good practices, engineering methods and standard instructions are followed.

This includes procurement of office furniture, electric and electronic equipment and materials (no bio-hazardous or low-radiological materials will be used for testing in this equipment).

Insignificant effect

Negative Determination with conditions. The implementer is required to ensure that equipment, commodities (also see ADS

312) and materials are procured from certified retailers; environmental safety and quality certificates conforming with national and/or international standards are available; equipment and materials are used in an environmentally sound and safe manner, properly disposed of when applicable at the end of their useful life in a manner consistent with best management practices according to USG, European Union or equivalent standards acceptable to USAID.

See IEE Tables 1 and 2 for more details.

III Activities that normally do not have a significant effect on the environment if special mitigation measures are specified to prevent unintended impact

Potential for a significant adverse effect of one or more

Negative Determination with conditions;

EDD in form of Environmental Review and

Examples include:

- Medical laboratories and centers upgrade; equipment procurement and installation; HIV and TB testing;

- Procurement and use of medical kits, supplies, and chemical reagents;

- Procurement and use of pharmaceutical drugs;

-Immunization campaigns including TA and vaccination;

-Small-scale construction/renovation of sanitation and health facilities;

- Small-scale water supply and water quality improvement activities (may include application of disinfectants that are registered as pesticides);

- Improved nutrition and feeding; and

- Generation, storage and disposal of hazardous wastes as part of various activities;

activities

Assessment Checklist (IEE Annex 1) is required to identify environmental effects, develop Environmental Manual and Mitigation and Monitoring Plans when applicable, confirm /neglect and mitigate a potentially significant adverse effect. If significant adverse effects are expected, a Scoping Statement (SS) and Environmental Assessment (EA) shall be conducted by the implementer prior to start of activities.

SOW/Terms of Reference (TOR) for Scoping Statement and EA Report must be reviewed by Mission Environmental Officer (MEO) and approved by Asia BEO.

For details, please see Section “Implementer Procedures” and IEE Section 4.

Note: EDD - Environmental Due Diligence Review

USAID/CAR’s Health portfolio is primarily technical assistance focusing on improving the quality of service delivery, government and NGO capacity building, and institutional strengthening, and is not expected to have a negative impact on the environment. The overall environmental determination for 90% of USAID/CAR health programming is Categorical Exclusion for activities that were found to present no risk according to 22 CFR 216 guidelines, and is Negative Determination with conditions for the remaining 10%.

a) Recommended Action: Categorical Exclusion (90% of funding) Pursuant to 22 CFR 216.2(c)(2)(i), the originator of the activities has determined that all of the activities consist of types of interventions entirely within the categories listed in paragraph (c)(2), “Categorical Exclusions,” of Section 216.2, “Applicability of Procedures,” of Title 22 CFR Part 216, “AID Environmental Procedures”, and therefore are categorically excluded from further environmental review requirements. The originator of the proposed action has further determined that the proposed activities are fully within the following classes of actions:

a. Education, technical assistance, or training programs except to the extent such program includes activities directly affecting the environment (such as construction of facilities, etc.) [22 CFR 216.2(c)(2)(i)];

b. Analyses, studies, academic or research workshops and meetings. [22 CFR 216.2(c)(2)(iii)];

c. Document and information transfers. [22 CFR 216.2(c)(2)(v)]; and

d. Studies, projects or programs intended to develop the capability of recipient countries to engage in development planning, except to the extent designed to result in activities directly affecting the environment (such as construction of facilities, etc.) [22 CFR 216.2(c)(2)(xiv)].

b) Recommended Action: Pursuant to 22 CFR216.3(a)(2)(iii), a Negative Determination with conditions (10% of funding) is recommended for any Health Care activities that have potential for adverse impact on the environment in the following categories, as presented in Section III of Table 2 of this document:

a. Procurement, storage, management and disposal of public health commodities, including pharmaceutical drugs, medical kits, supplies and chemical reagents;

b. Generation, storage and disposal of hazardous or highly hazardous medical waste, e.g. HIV testing, TB testing and laboratory-related activities;

c. Small-scale construction/rehabilitation of health facilities;

d. Small-scale water and water quality assurance activities;

e. Immunization campaigns (might include procurement of vaccine and its administration thereof, storage, distribution, and waste disposal); and

f. Improved nutrition and feeding

For each type of these activities an implementer will conduct Environmental Due Diligence (EDD) as part of the Environmental Review and Assessment Checklist (Annex

1) to document existing environmental concerns and foreseeable environmental effects resulting from the activity and develop an Environmental Manual (EM) and Framework Environmental Mitigation and Monitoring Plan (FEMMP) when applicable. This EM and FEMMP will then be approved by the MEO, in consultation with the Asia & OAPA Regional Environmental Advisor (REA), adapted to a specific site before the activity implementation (site specific EMMP), and incorporated into the project design. The Standard Conditions List in Annex 3 and IEE Table 2 of this IEE may be used as a guide in developing of EM, FEMMP, and EMMP along with other references listed in Implementer Procedures section.

Implementer Procedures:

The implementing partner will employ the following process for all relevant activities:

All program activities will seek to raise environmental awareness, promote regional and national environmentally and socially sustainable development, biodiversity conservation, adaptation to climate change, foster the culture of environmental compliance and governance, in accordance with The UNECE Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters with reference to it:

http://www.unece.org/env/pp/welcome.html

The implementer will include environment compliance considerations into all aspects of the program implementation and will promote and train local counterparts on environmental requirements and standards across all of the program’s activities. Such proposed activities will be included into annual work plans, and results will be reported in annual reports.

Each activity should be conducted in a manner consistent with good design and implementation practices described in USAID Environmental Guidelines for Small-Scale Activities in Africa, 2nd edition as provided at:

http://www.encapafrica.org/egssaa.htm; IFC Environmental, Health and Safety Guidelines as provided at:

http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines; World Health Organization guidelines as provided at http://www.who.int/publications/guidelines/environmental_health/en/index.html;

and Standard Conditions for Small-Scale Construction, Small-Scale Road Rehabilitation, Small- Scale Water and Wastewater Activities, attached to this IEE (Annex 3).

Based on EDD results and mitigation measures from Environmental Guidelines for small-scale Activities, IFC EHS Guidelines, World Bank PPAH, and other documents as referenced above, implementer will develop Program Environmental Manual (EM) and Framework Environmental Mitigation and Monitoring Plan (FEMMP) for activities that may have negative environmental impact. EM will establish criteria for eligibility, selection and screening against potential environmental risk (low, moderate, and high). An EM and FEMMP might be done per implementing partner or the whole program and then adapted as needed for different implementing partners. This documentation will then be approved by the MEO, in consultation with the Regional Environmental Advisor for Asia (REA/Asia), incorporated in project design and FEMMP will be adapted to a specific site prior to the activity implementation (EMMP) (see IEE Annex 4).

The implementer will use the Environmental Review and Assessment Checklist (ER Checklist) (IEE Annex 1) and Leopold Matrix (IEE Annex 2) as the main reporting documents for each activity having an adverse environmental impact.

Prior to the launch of each activity including small grants and subcontracts, the implementer will conduct an Environmental Due Diligence (EDD) review as an inherent part of the ER Checklist for each activity that may have a potential for moderate and high adverse environmental impact (e.g. small-scale construction;, rehabilitation of potable water and sanitation facilities; etc.) to document existing environmental concerns and foreseeable environmental effects resulting from such types of activities. If the EDD results in a finding of potential significant environmental impact, a Scoping Statement (SS) and Environmental Assessment (EA) will be done by the implementer prior to start of activities. TOR for Scoping Statement, Scoping Statement and EA Report must be reviewed by MEO and approved by Asia BEO.

As part of its initial Work Plan, and all Annual Work Plans thereafter, the implementer, in collaboration with the USAID Agreement/Contracting Officer’s Representative (A/COR) and MEO shall review all ongoing and planned activities under this award to determine if they are within the scope of the approved IEE;

and classify them in accordance with Table 2 and IEE Section 3.

When appropriate, the implementer will have a qualified, MEO-approved environmental impact professional(s) (EIP) who will assess and recommend environmental actions to be taken by the program and will coordinate implementation of mitigation measures, monitoring, and reporting. Specifically, the EIP will conduct environmental reviews and will identify: 1) activity category in consultation with the MEO; 2) potential environmental impacts (based on ER Checklist, EDD, Leopold Matrix, and his/her technical knowledge of the local, U.S., and international environmental standards, guidelines, requirements, and practices; and 3) mitigation and monitoring measures needed. Should the EIP lack special technical knowledge to identify any special environmental impact, the implementer will consult with a specialist in the relevant area.

Documenting environmental baseline conditions prior to activity implementation is an integral part of the site specific EMMP.

Host country laws and regulations for environmental protection and management will be followed in implementing the activities. For activities categorized as “potential risks”' or “definite risks” of adverse environmental impact, the implementing partner will be required to obtain a letter from the local or regional office for environmental protection stating that the office: a) has been contacted by the implementing partner concerning the project activities; b) will maintain contact with the project; and c) will be aware of the potential environmental impacts of the project to help ensure that no detrimental impact will result from this project.

For such activities prior to their implementation the implementer will conduct public consultations and will seek concurrence from the national duly authorized environmental agency on FEMMPs and EMMPs.

In all cases, implementation will adhere to corresponding host country environmental laws and policies, generally outlined in national Ministry of Health “SanPin” (Sanitary Epidemiological, or СанПиН) documents. The following are links to SanPin documents available online:

o Kazakhstan:

http://www.mz.gov.kz/index.php?wakka=Rus/SanitarnoJepidemiologicheskijjNa dzor/NPACT/Infonpa&v=u5e o Kyrgyzstan: http://www.med.kg/Articles/ViewSection.aspx?ArticleID=230 o Uzbekistan:

http://www.minzdrav.uz/documentation/list.php?SECTION_ID=141

Monitoring will be conducted during the project (beginning with a baseline) to determine the environmental impact (positive and/or negative) of all project activities. The implementer shall use only qualified staff for overseeing the mitigation and monitoring work. Monitoring shall occur on an as-needed basis.

The implementer will ensure that the environmental procedures are implemented, potential impacts mitigated, and indirect and cumulative effects are considered for each activity. If negative environmental impacts are discovered through regular monitoring and evaluation of project activities, immediate actions will be taken to rectify the situation.

The implementer shall have sufficient resources and permanent staff with expertise in an environmental field and compliance with Reg. 216.

Resource Allocation, Training and Reporting requirements:

The agreement/contract with the implementing partner will include environmental compliance and reporting language into agreements/contracts, and ensure that appropriate resources, staff, equipment and reporting procedures are dedicated to this portion of the project; the language will have a requirement to follow all recommendations of this IEE, including completed Environmental Review and Assessment Checklist, and EM and FEMMP, site specific mitigation and monitoring plans, and mitigation and monitoring reports. Reports will be submitted to the Agreement/Contracting Officer’s Representative (A/COR) and MEO prior to and at the completion of each relevant activity at every affected project site, and not at the end of the project or not on a semi-annual or annual basis.

Sub-contracts or grants from the implementing partner to other organizations must incorporate provisions stipulating compliance with 22 CFR 216 and ADS 204.

The A/COR of each project, in consultation with the MEO or REA and corresponding implementing partner(s), will actively monitor and evaluate whether environmental consequences not foreseen by this IEE arise during implementation, and will modify or halt activities as appropriate. If additional activities are added to a project but are not described in this IEE, an amended IEE must be prepared.

When deemed necessary by the A/COR and MEO, reporting will include photographic documentation and site visit reports which fully document that all proposed mitigation procedures were followed throughout implementation of the subject work including quantification of mitigation.

The implementer’s quarterly reports to USAID shall contain a section specific to

Environmental Compliance will include project summaries along with environmental impacts, success or failure of mitigation measures being implemented, results of environmental monitoring, and any major modifications/revisions to the project, mitigation measures or monitoring procedures. If the activities implemented do not have any negative impact on the environment, this should be documented as well. The implementer’s annual report will include an annex containing a table indicating the title, date of award, and category of each grant activity.

A/CORs together with MEO/Deputy MEO will explain all environmental conditions to the implementers at the post-award conference. The Mission will also arrange for Environmental Compliance Training for the implementer(s) by the MEO prior to the start of the project implementation.

Limitations of the IEE:

1. All reagents, disinfectants and other chemicals, registered by US EPA, as pesticides shall be procured, used or recommended for use only in accordance with BEO-approved Programmatic Pesticide Evaluation Report and Safe use Action Plans (PERSUAPs) for Kyrgyzstan, Tajikistan, Turkmenistan, and Uzbekistan. If any additional chemicals are proposed, relevant Programmatic PERSUAPs shall be amended and approved by the BEO/Asia. The IEE shall be amended to reflect on the recommendations of the Programmatic PERSUAP, and approved by the BEO/Asia. For Kazakhstan, the implementer will request the BEO/Asia approval to extend validity of relevant CAR Programmatic PERSUAP sections to stipulate compliance with relevant Kazakhstan legislation.

2. No procurement, use or recommendation for use of ammonium nitrate (AN) and calcium nitrate (CAN) fertilizers.

3. No procurement or use of Asbestos Containing Materials (ACM) (i.e. piping, roofing, etc), Polychlorinated Biphenyl’s (PCB) or other toxic/hazardous materials prohibited by US EPA including lead or mercury containing materials as provided at: http://www.epa.gov/asbestos and/or under international environmental agreements and conventions, e.g. Stockholm Convention on Persistent Organic Pollutants as provided at: http://chm.pops.int.

4. This IEE does not cover activities involving:

a. support to wood processing, agro-processing, industrial enterprises, and regulatory permitting;

b. assistance, procurement or use of genetically modified organisms (GMOs), which would require preparation of biosafety assessment (review) in accordance with ADS 201.3.12.2(b) in an amendment to the IEE approved by Asia BEO; or

c. DCA or GDA programs.

Any of these actions would require an amendment to the IEE duly approved by Asia

BEO.

Revisions:

Pursuant to 22CFR216.3(a)(9), if new information becomes available which indicates that activities to be funded by the project might be “major” and the project’s effect “significant,” this negative determination will be reviewed and revised by the originator of the project and submitted to the Bureau Environmental Officer for approval and, if appropriate, an environmental assessment will be prepared.

USAID APPROVAL OF ENVIRONMENTAL ACTION(S) RECOMMENDED:

Clearance:

Regional Mission Director: ____________________ Date: ________

Erin Elizabeth McKee

Kyrgyzstan USAID Representative: cleared by e-mail Date: 9/26/2012

Carey Gordon

Tajikistan Acting Country Office Director: cleared by e-mail Date: 9/27/2012 Charles Specht

Turkmenistan Country Office Director: cleared by e-mail Date: 9/26/2012

Benjamin Chapman

Uzbekistan Acting Country Office Director: cleared by e-mail Date: 9/26/2012

Alison Kosnett

Regional Environmental Advisor for Asia & OAPA: cleared by e-mail Date: 9/24/2012

Andrei Barannik

HEO Director: ________________ Date: ________ Leslie Perry

USAID/CAR Mission Environmental Officer: ________________ Date: ________

Nina Kavetskaya

COR: Quality Health Care Project: cleared by e-mail Date: 9/25/2012

Kairat Davletov

AOR: Dialogue on HIV and TB Project: cleared by e-mail Date: 9/27/2012

Khorlan Izmailova

AOR: MCH APS, WHO Polio: cleared by e-mail Date: 9/25/2012

Sholpan Makhmudova

AOR: WHO Tuberculosis PIO: cleared by e-mail Date: 9/27/2012 Christina Lau