Attachment_J.7._Initial_Environmental_Examination_(IEE).PDF

USAID Afghanistan - IHSSSP 1

U.S. AGENCY FOR INTERNATIONAL DEVELOPMENT

OFFICE OF AFGHANISTAN AND PAKISTAN

INITIAL ENVIRONMENTAL EXAMINATION

PROGRAM/ACTIVITY DATA

Country Code and AO: 306-002

Assistance Objective Name: Improved Health of the Population

Program Objective: Investing in People

Program Area: Health

Program Element: Family Planning & Reproductive Health; Maternal and Child Health;

Other Public Health Threats; Tuberculosis

Country or Region: Afghanistan

Activity Name: Integrated Health Services & System Strengthening Program, Phase 1

(IHSSSP 1)

Funding Begin: o/a 4/2014 Funding End: o/a 12/2018 LOP Amount: $430,000,000

IEE Prepared by: Mohammad Shapor Ikram Date: 03/07/2013

IEE Amendment (Y/N): N

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)

Categorical Exclusion Deferral

Positive Determination Negative Determination

Negative Determination with Conditions Exemption

1. PURPOSE, BACKGROUND, AND ACTIVITY DESCRIPTION

1.1 Purpose and Scope of IEE

The purpose of this Initial Environmental Examination (IEE), in accordance with 22 CFR 216, is to provide the first review of the reasonably foreseeable effects on the environment, as well as the recommended Threshold Decision for the Integrated Health Services & System

Strengthening Program, Phase 1 (IHSSSP 1). This IEE provides a brief statement of the basis for the Threshold Decision as to whether an Environmental Assessment or an Environmental Impact

Statement is required for the subject project. A number of activities are recommended for categorical exclusion, including all on-budget activities implemented through the World Bank

USAID Afghanistan - IHSSSP 1 2

(WB) managed Afghanistan Reconstruction Trust Fund/System Enhancement for Health Action in Transition (ARTF/SEHAT) project, while others have received a negative determination with conditions.

1.2 Background and Project Description

Although gains in the health sector have been significant, Afghans continue to face serious health challenges. To address these ongoing public health challenges in Afghanistan, USAID will build on and consolidate effective and successful gender-sensitive approaches that have yielded significant results to date. Even in the midst of humanitarian crisis, a decade of support from USAID and other donors was focused on capacity building and MoPH stewardship from the outset. As the Ministry of Public Health (MoPH)’s program matured over the past decade, USAID support has responded to the changing needs of the health program. There is a need to safeguard the fragile gains and investments made to date, and to continue to strengthen health systems, health financing options, and MoPH human resource development capacity. Past investments focused on increasing the coverage of services and number of health providers;

going forward, USAID support will be more nuanced, focusing on refining approaches, targeting underserved populations, expanding emphasis on the quality of gender-sensitive training and services, reducing duplication by harmonizing and consolidating quality improvement approaches and communication messages and emphasizing health systems strengthening.

Additional efforts will consolidate MoPH capacity for procurement, management and oversight of the system.

USAID’s new program of assistance, the Integrated Health Services and System Strengthening

Program, Phase 1 (IHSSSP 1), is the first phase of a new, ten-year program that the Office of

Social Sector Development (OSSD) has designed to meet ongoing health needs and challenges.

It encompasses both on- and off-budget activities over a five-year period (2014-18) and will result in the award of an on-budget project through the ARTF/SEHAT and off-budget technical assistance projects designed to support the accelerated transition of selected assistance activities to MoPH on-budget programs as well as the continued strengthening of MoPH capacity to manage its expanded on-budget program.

IHSSSP 1 will continue to improve access to, and availability of, quality Basic Package of

Health Services (BPHS) and Essential Package of Hospital Services (EPHS), particularly for women and children, and will place special emphasis on strengthening community participation in order to ensure improved governance and accountability, and increasing sustainability through health care financing schemes and public-private partnerships. In addition, the program will increase demand for quality services and promote healthy behaviors. Increased MoPH stewardship at both the central and provincial levels is a high priority that will result in increased sustainability and institutionalization of the health program. Finally, the program will further strengthen the private sector to provide quality services and products at affordable prices. These results are captured below in four program areas which will contribute to – and are directly aligned with – the achievement of USAID’s Assistance Objective 2, Improved Health of the

Population with a Special Focus on Women and Children.

USAID Afghanistan - IHSSSP 1 3

As stated above, IHSSSP has two major components, on-budget through ARTF/SEHAT and off-budget through implementing partners. These two components will be addressed separately below:

ON-BUDGET COMPONENT (TOTALFUNDING $279,169,198)

The on-budget mechanism encompasses both service delivery, technical assistance to the MoPH, and program support. It will be carried out through ARTF and will be beyond the direct control of USAID.

OFF-BUDGET COMPONENT (TOTAL FUNDING $150,830,802)

The off-budget mechanism has the following program areas and illustrative activities:

Program Area 1 - Effective Utilization of BPHS and Other Client-Oriented Health Services

Increased: Increasing the utilization of quality health services is critical to accelerating the gains made to date and to further reductions in maternal, infant and child mortality. USAID will achieve this by building on and consolidating effective activities in support of the BPHS and

EPHS package. USAID’s investments will focus on the provision of quality BPHS and EPHS services in the 13 USAID-supported provinces and continue to strengthen the MoPH’s capacity to tackle communicable diseases that disproportionally affect women and children.

Priority areas will include (a) strengthening the technical knowledge and capacity of the MoPH at central and provincial levels to support BPHS/EPHS service delivery; (b) strengthening the technical capacity of BPHS and EPHS service providers to scale up health services; (c) identifying and applying innovative and cost-effective approaches to improving access to services in underserved areas and among hard-to-reach populations (due to insecurity, geographic disparities, etc.); and (d) strengthening the number and capacity of nursing and midwifery programs to fill the gap in skilled female providers.

Illustrative Activities:

Increase the availability of female and male community health workers and skilled health providers, particularly female providers such as community midwives, through training, technical assistance to professional associations, and technical assistance to improve pre-service and in-service training programs as well as retention following deployment.

Empower BPHS/EPHS NGOs with the ability (funds and authority) to contract out for clinical and non-clinical in-service training for health providers, which will incorporate gender awareness and gender-sensitive practices and communication.

Scale-up innovative, cost-effective community-based health care interventions through technical assistance, training, and printing of select materials.

Provide technical assistance to the MoPH at all levels to identify innovative and cost-effective approaches to addressing specific challenges to health care access.

USAID Afghanistan - IHSSSP 1 4

Program Area 2 - Private Sector Health Services and Products Strengthened: The MoPH will collaborate with the private sector to achieve significant improvement in the overall health outcomes of the Afghan population. The objective of the private health sector component of

IHSSSP is to improve the capacity of the private sector to provide an increasing range of quality health products and services to the Afghan population. This priority program area will focus on access to high quality and affordable health products and services; advocacy on and improving the policy and regulatory environment in the private sector; monitoring and evaluation;

continued development of the Afghan Social Marketing Organization (ASMO); and technical assistance to the MoPH’s Office of Private Sector Coordination to develop public-private partnerships (PPPs) in the health sector, among other activities.

Conduct feasibility studies for the identification and design of hospital PPPs.

Strengthen the capacity of the MoPH Office of Private Sector Coordination to regulate and monitor the private sector, and the capacity of the private sector to regulate and monitor itself, through technical assistance.

Expand access to and increase demand for quality, affordable health care products through social marketing; activities will include distribution and sale of products such as contraceptives, advertising, production of behavior change materials and capacity building – via technical assistance and training – of ASMO.

Program Area 3 - GIRoA Stewardship of the Health System Improved: The third component of the IHSSSP program will focus on strengthening the health systems and governance capacity of the MoPH at the central and provincial levels to better support the provision of quality health services to the Afghan people, and to sustain gains in health outcomes beyond the period of donor assistance. This priority program area will focus on (a) strengthening managerial and leadership capacity, and empowering the MoPH at central and provincial levels, to: support health service delivery, including improved decision-making, and improved resource and financial allocations; identify local solutions to provincial/district level-identified problems and challenges; and enable the MoPH at those levels to work with municipalities and reach out to communities; and (b) accelerating health care financing efforts in order to reduce heavy donor dependency in the sector. The IHSSP will develop and implement specific interventions that are gender-sensitive and gender–aware in order to address these constraints. USAID will partner with the MoPH to ensure the Government’s capacity to maintain access to quality health services and medical products; track progress with a strong health management and information system;

and build its self-sufficiency and legitimacy to deliver key health services at all levels.

Strengthen MoPH functions in key areas through technical assistance and training (areas include service delivery); policy formulation; administration; financing and procurement;

advocacy; strategic planning; monitoring; strategic communication; information collection and management; human resource allocation; and coordination among directorates and provinces, ministries and donors.

USAID Afghanistan - IHSSSP 1 5

Build the capacity of the MoPH – through technical assistance, training and special studies which provide data for decision-making -- to become self-sustaining through hospital autonomy, social and community health insurance, public-private partnerships, and the development of innovative health financing options.

Continue to build the capacity of the MoPH in pharmaceutical/contraceptive supply chain management and procurement through technical assistance in forecasting/ordering/ storing/managing/distributing commodities.

Foster provincial- and district-level MoPH and community working relationships in identifying and addressing local constraints/problems and in holding the MoPH accountable for results and high-quality service delivery that addresses community needs.

Activities will include technical assistance, workshops, and meetings.

Program Area 4 - Healthy Behaviors Adopted: Limited knowledge and poor understanding of MNCH, reproductive health, child survival, and of protective behaviors against infectious and communicable diseases results in inadequate home-based care and limited use of community-and clinic-based services. An emphasis on prevention and health literacy, combined with efforts to increase community participation in, and ownership of, health promotion, is an empowering, cost-effective strategy; it improves knowledge and awareness, changes attitudes, increases the adoption of optimal practices by individuals and families for their own protection, and strengthens the quality of health services as well as the responsiveness of those services to community health needs. Priority areas will include: (a) building technical capacity within the

MoPH to play a leadership role in implementing its existing national communications strategy, and to respond to current and emerging health promotion needs; (b) strengthening the capacity of

BPHS/EPHS service providers to implement the communication strategy and to mobilize communities; and (c) improving knowledge and attitudes about healthy behaviors at the individual (both men and women), family, community, provider, district, provincial and national levels. Past investments focused on the development of messages and information/ education/communication materials within the health sector.

Support the Health Promotion Department to implement and monitor the National Health and Nutrition Communication Strategy, and to respond to current and emerging health promotion needs. Activities will include technical assistance, workshops, and data analysis.

Mobilize influential rural and urban community level actors to undertake effective health promotion activities in support of priority health objectives, programs and interventions, and to increase ownership of health. Activities will include technical assistance, workshops and community meetings, and training.

2.0 COUNTRY AND ENVIRONMENTAL INFORMATION

2.1 Environment Law of Afghanistan, 2007

USAID Afghanistan - IHSSSP 1 6

The Environment Law requires GIRoA to adopt necessary measures to protect the natural environment and living conditions of the country. The National Environmental Protection

Agency (NEPA) is responsible for the implementation of this law. Following international best practices, NEPA mandates that new activities are screened for potential adverse effects and possible impacts and, if such impacts are likely, a comprehensive mitigation plan is developed for review and approval before the activity can proceed.

2.2 Overall Assessment of the Health System

Small-scale healthcare activities, such as rural health posts, basic health facilities, and urban clinics and small hospitals, provide important and often critical healthcare services to individuals and communities that would otherwise have little or no access to such services. They are the front line of defense against epidemics and a key component of any comprehensive development program. The medical and health services they provide improve family planning, nurture child and adult health, prevent disease, cure debilitating illnesses, and alleviate the suffering of the dying.

2.3 Waste Management in Health Systems

In many areas, little or no management of healthcare wastes occurs in small-scale facilities.

Training and supplies are minimal. Common practice in urban areas is to dispose of healthcare waste along with the general solid waste or, in peri-urban and rural areas, to bury waste, without treatment, in unlined pits. In some cities, small hospitals may incinerate waste in dedicated on-site incinerators but often fail to operate them properly. Unwanted pharmaceuticals and chemicals may be dumped into the local sanitation outlet, be it a sewage system, septic tank or latrine.

2.4 Most At-Risk Groups

Transmission of disease through infectious waste is the greatest and most immediate threat from healthcare waste. If waste is not treated to destroy pathogenic organisms, dangerous quantities of microscopic disease-causing agents—viruses, bacteria, parasites or fungi—will be present in the waste. These agents can enter the body through breaks in the skin, mucous membranes in the mouth, through inhalation, swallowing, or transmission by a vector organism.

Those who come into direct contact with the waste are at greatest risk. Examples include healthcare workers, cleaning staff, patients, visitors, waste collectors, disposal site staff, waste pickers, drug addicts, and those who knowingly or unknowingly use “recycled” contaminated syringes and needles.

Although sharps pose an inherent physical hazard of cuts and punctures, the much greater threat comes from sharps that also are infectious waste. Again, healthcare workers, waste handlers, waste-pickers, drug addicts and others who handle sharps can, and have, become infected with

HIV/AIDS and hepatitis B and C viruses through pricks or reuse of syringes/needles. These infections may be fatal.

USAID Afghanistan - IHSSSP 1 7

Contamination of water supply from untreated healthcare waste can also have devastating effects. If infectious stools or bodily fluids are not treated before being disposed of, they can create and extend epidemics, since sewage treatment in Afghanistan is almost nonexistent.

2.5 Lessons learned

There is a general lack of standard environmental policy implementation and weak and substandard waste management systems in the country and the health system is no exception.

Although the MoPH has introduced some limited measures, regarding infection prevention and the safe disposal of medical wastes produced by the hospitals and small health facilities, there is general lack of professional environmental health capacity, regulations, and enforcement in the

MoPH leading to a lack of proper policies and procedures for environmental protection. Safe disposal of used and unused medical equipment, particularly those with the potential for environmental hazards is of special concern. As a practice, all used and defected medical equipment is dumped in storage and remain there for years and there are no standard procedures in place to remove hazardous materials from the old and disused equipment. Periodically, the

MoPH conducts auctions and sells unusable equipment; however, the fate of this equipment, especially those containing hazardous materials such as X-Ray machines, is unclear. Future awards and sub-awards should include a clause concerning environmental protection and safe disposal of hazardous materials accompanied by a fund allocation for this purpose. Performance monitoring should include particular attention to medical waste disposal and periodic refresher training should be provided to MoPH staff and NGO implementers.

3.0 EVALUATION OF PROJECT ACTIVITIES WITH RESPECT TO

ENVIRONMENTAL RISK

Project activities, their effects on the environment and 22 CFR 216 determination and actions required are summarized in the table below.

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Table 2: Environmental determinations of project activities

Component

Program

Area Activities

Effect on

Natural or

Physical

Environment

Determination and Reg.

216 actions required

On-Budget N/A various Unknown 22 CFR 216.2 (c)(1)(ii): no action required

NOTE: USAID will rely on the environmental procedures of

World Bank and ARTF as documented in the RCE for

ARTF, approved on March 14, 2013, tracking # OAPA-13-

MAR-AFG-0026

Off-Budget 1 Provide quality BPHS and

EPHS services in 13 USAID-supported provinces and continue to strengthen the

MoPH’s capacity to tackle communicable diseases that disproportionally affect women and children.

No impact

§216.2(c)(2)(i):

Technical assistance: no action required

§216.2(c)(2)(iii):

Analysis, studies, academic or research workshops: no action

§216.2(c)(2)(v):

Document and information transfers: no action required

Off-Budget 2 Improve the capacity of the private sector to provide an increasing range of quality health products and services through a focus on access to high quality and affordable health products and services;

advocacy on and improving the policy and regulatory environment in the private sector; monitoring and evaluation; continued development of the Afghan

Social Marketing

Organization; and technical assistance to the MoPH’s

Office of Private Sector

Coordination to develop public-private partnerships.

No impact §216.2(c)(2)(i):

Off-Budget 3 Strengthen the health systems No impact §216.2(c)(2)(i):

USAID Afghanistan - IHSSSP 1 9 and governance capacity of the MoPH to better support the provision of quality health services and to sustain gains in health outcomes beyond the period of donor assistance.

Off-Budget 4 Focus on prevention and health literacy, and efforts to increase community participation in, and ownership of, health promotion.

Improper storage management and disposal of expired medicines leads to environmental contamination and may pose health hazards

Negative Determination with

Conditions per 22 CFR

216.3(a)(2)(iii)

Conditions: Disposal of expired medicines will follow USAID minimum acceptable standards as set forth in Environmental

Guidelines for Small –Scale

Activities in Africa Chapter

II.08 on Health Care Waste, http://www.encapafrica.org/egs saa.htm, and will comply with

WHO Guidelines for the

Disposal of Unwanted

Pharmaceuticals in and after an

Emergency, http://www.who.int/water_sanit ation_health/medicalwaste/unw antpharm.pdf. These are the current guidelines used by the

MoPH. Expired pharmaceuticals are delivered to the MoPH/General

Directorate for Pharmaceutical

Affairs (GDPA) for burning and burying in a designated landfill. The amount of expired pharmaceuticals to be disposed is expected to be extremely low.

4.0 RECOMMENDED THRESHOLD DECISIONS

a) Recommended Action: Categorical Exclusion

On budget activities: On-budget activities through ARTF managed by the WB will receive a categorical exclusion based on 22 CFR 216.2 (c)(1)(ii), because “AID does not have knowledge of or control over, and the objective of AID in furnishing assistance does not require, either prior to approval of financing or prior to implementation of specific activities, knowledge of or control over, the details of the specific activities that have an effect on the physical and natural environment for which financing is provided by AID.”

http://www.encapafrica.org/egssaa.htm http://www.encapafrica.org/egssaa.htm http://www.who.int/water_sanitation_health/medicalwaste/unwantpharm.pdf http://www.who.int/water_sanitation_health/medicalwaste/unwantpharm.pdf

USAID Afghanistan - IHSSSP 1 10

A Request for Categorical Exclusion (RCE) for ARTF was approved by the BEO on March 14, 2013, tracking # OAPA-13-MAR-AFG-0026.

On-budget activities through ARTF are therefore exempted from USAID’s requirement to conduct an initial environmental examination, environmental assessment or environmental impact statement. USAID will rely on WB’s safeguard policies

(http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/EXTPOLICIES/EXTOPMANUA

L/0,,menuPK:64701637~pagePK:51628525~piPK:64857279~theSitePK:502184,00.html) to ensure compliance with its own safeguard policies and procedures as well as ensure that environmental and social framework procedures are developed and approved to cover all activities to be funded through ARTF.

In case the implementation results and compliance are found to be lacking or insufficient to

USAID’s standards, further contributions to ARTF may be halted.

Off-budget activities: IHSSSP 1 off-budget activities that receive a categorical exclusion are training, workshops, studies and assessments that are conducted to improve capacity of the

MoPH to manage and supervise the health system and to improve primary health care services at the community-level and through the private sector.

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

Analyses, studies, academic or research workshops and meetings. [22 CFR

216.2(c)(2)(iii)];

Document and information transfers: no action required [216.2(c)(2)(v)]

b) Recommended Action: Negative Determination with Conditions

Off-budget activities: Two activities, the disposal of medical waste and the provision of essential medicines, have the potential to directly or indirectly affect the environment. For these activities, a negative determination with conditions is recommended based on 22 CFR

216.3(a)(2)(iii). The proposed action is that the off-budget implementer will follow USAID minimum acceptable standards as set forth in Environmental Guidelines for Small –Scale

Activities in Africa Chapter II.08 on Health Care Waste, http://www.encapafrica.org/egssaa.htm, and will comply with WHO Guidelines for the Disposal of Unwanted Pharmaceuticals in and after an Emergency, http://www.who.int/water_sanitation_health/medicalwaste/unwantpharm.pdf.

5.0 CONDITIONS AND IMPLEMENTERS’ PROCEDURES

1. The implementer shall be responsible for implementation of all recommendations resulting from this IEE.

2. Each activity should be conducted in a manner compliant with all applicable legislation;

regulation and standards of Afghanistan; national obligations under ratified applicable http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/EXTPOLICIES/EXTOPMANUAL/0,,menuPK:64701637~pagePK:51628525~piPK:64857279~theSitePK:502184,00.html http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/EXTPOLICIES/EXTOPMANUAL/0,,menuPK:64701637~pagePK:51628525~piPK:64857279~theSitePK:502184,00.html http://www.encapafrica.org/egssaa.htm

USAID Afghanistan - IHSSSP 1 11 international environmental agreements and conventions; and in their absence with best management and industry practice acceptable to USAID.

3. The implementer(s) shall minimize the use of, and properly dispose of, hazardous materials and wastes.

4. When equipment (computers; etc.) is procured, at the end of its life, it should be disposed in an environmental safe manner by a certified company in accordance with the GIRoA laws, and in their absence, in accordance with international best practice acceptable to

USAID (alternatively, when procuring equipment from a licensed provider/dealer, an agreement may be reached that such equipment will be returned to the dealer for its environmentally safe disposal).

5. As appropriate, the implementers will obtain necessary environmental compliance documentation, including applicable permits, licenses, etc.

6. All activities will be consistent with good design and implementation practices acceptable to USAID as described in:

a. USAID’s Environmental Guidelines for Small-Scale Activities in Africa; 2nd edition as provided at http://www.encapafrica.org/egssaa.htm; additional background available at http://www.usaid.gov/our_work/environment/compliance

b. EBRD Sub-sectoral Environmental and Social Guidelines at http://www.ebrd.com/pages/about/what/policies/guidelines.shtml

c. ADB Environmental Guidelines at http://www.adb.org/sites/default/files/pub/2003/Environmental_Assessment_Guid elines.pdf

d. IFC Environmental; Health and Safety Guidelines as provided at http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines;

e. World Bank Road and the Environment Handbook as provided at: http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTTRANSPORT

/EXTROADSHIGHWAYS/0,,contentMDK:20457855~menuPK:1459669~pageP

K:148956~piPK:216618~theSitePK:338661,00.html

f. World Bank environmental Handbook and Updates at http://go.worldbank.org/LLF3CMS1I0

g. Any other international best practices if readily available, such as those of OECD, UNEP/UNDP or EU.

7. The implementer will have a qualified, Mission Environmental Officer (MEO)-approved

Environmental Professional (EP) who coordinate implementation of environmental mitigation measures, monitoring, and reporting to the USAID/Afghanistan COR/AOR.

Should an EP lack any special technical knowledge to identify any special environmental impact, the implementer will consult with a specialist in the relevant area.

8. Continuous environmental monitoring, evaluation, reporting and supervision will be conducted during the project implementation. Quarterly, semi-annual and annual reports, as applicable, will contain sections on environmental compliance. The implementers will submit an Environmental Mitigation and Monitoring Plan (EMMP) within 30 days of the signing of the award. An EMMP template is provided in Annex I.

9. COR and MEO will meet with individual implementers to explain conditions established in the original and amended IEEs.

6.0 RESOURCE ALLOCATION; TRAINING AND REPORTING REQUIREMENTS

http://www.encapafrica.org/egssaa.htm http://www.usaid.gov/our_work/environment/compliance http://www.ebrd.com/pages/about/what/policies/guidelines.shtml http://www.adb.org/sites/default/files/pub/2003/Environmental_Assessment_Guidelines.pdf http://www.adb.org/sites/default/files/pub/2003/Environmental_Assessment_Guidelines.pdf http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTTRANSPORT/EXTROADSHIGHWAYS/0,,contentMDK:20457855~menuPK:1459669~pagePK:148956~piPK:216618~theSitePK:338661,00.html http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTTRANSPORT/EXTROADSHIGHWAYS/0,,contentMDK:20457855~menuPK:1459669~pagePK:148956~piPK:216618~theSitePK:338661,00.html http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTTRANSPORT/EXTROADSHIGHWAYS/0,,contentMDK:20457855~menuPK:1459669~pagePK:148956~piPK:216618~theSitePK:338661,00.html http://go.worldbank.org/LLF3CMS1I0

USAID Afghanistan - IHSSSP 1 12

1. The contract with the implementer will include a requirement to comply with all conditions of the IEE and any other environmental mitigation and monitoring documentation approved by the Bureau Environmental Officer (BEO)/OAPA. The implementer will be responsible for training its staff and sub-contractors on the contract’s environmental requirements and for ensuring compliance of the environmental requirements.

2. The implementer shall have sufficient staff with expertise in an environmental field and resources to implement and report on the expected scope of environmental compliance work. The implementer will document, using cameras/photos, schemes and maps, the status of environmental (and social) conditions on site and in the area of influence prior to, during and after implementation of projects and activities. This evidence may be also used for providing USAID and GIRoA with lessons learned and best practices.

3. The implementer will have the following documentation and reporting requirements associated with the environmental compliance:

a. Annual Work Plans will have a section on the planned activities related to environmental compliance.

b. Progress Reports will have a section on the status of activities related to environmental compliance and results, including 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. Implementers’ annual report will include an annex containing a table indicating the title, date of award, and category of each activity, and status of mitigation measures and monitoring results, when applicable.

c. Final Report will have a section that will summarize program activities related to environmental compliance and will describe results, including information on any positive or negative environmental effects of program activities.

d. Site-specific Mitigation and Monitoring Reports will be submitted to USAID at the completion of each phase of work, and not on an annual basis. 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. All such reports and documentation will be submitted to the A/COR and MEO.

7.0 MONITORING AND MITIGATION MEASURES

Mitigation measures are required prior to funding or implementation of all activities recommended for a negative determination with conditions. The conditions for funding and implementation of these activities serve as the required mitigation measures for each activity and are specified in the previous section. The conditions also specify monitoring measures to ensure that the mitigation measures are; a) implemented and b) effective as a means of reducing or eliminating any adverse environmental impacts.

Project monitoring is required as a condition for all activities recommended for categorical exclusion or a negative determination with conditions. The MoPH will be required to develop

EMMPs acceptable to USAID, a form of which is contained in Annex I. In addition, USAID/Afghanistan will conduct periodic verification of environmental monitoring according to

USAID Afghanistan - IHSSSP 1 13 the requirements of the IEE. The verification should be conducted by the project COR/AOR in consultation with the MEO.

8.0 LIMITATIONS OF THE IEE

This assistance does not cover activities involving:

Assistance, procurement or use of genetically modified organisms (GMOs), which will require preparation of bio-safety assessment (review) in accordance with ADS

201.3.12.2(b) in an amendment to the IEE approved by BEO/OAPA.

Development Credit Authority (DCA) or Global Development Alliance (GDA) programs.

Procurement or use of Asbestos Containing Materials (ACM) (e.g., piping, roofing), Polychlorinated Biphenyl’s (PCB) or other hazardous materials prohibited by US EPA 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.

Procurement or use of pesticides.

Procurement or use of Ammonium Nitrate and Calcium Ammonium Nitrate fertilizers

9.0 REVISIONS

Pursuant to 22 CFR 216.3(a)(9), if new information becomes available which indicates that activities to be funded by the program might be “major” and the program’s effect “significant,” or if additional activities are proposed that might be considered “major” and their effects significant, this IEE will be reviewed and revised by the originator of the project and submitted to the BEO for approval and, if appropriate, an environmental assessment will be prepared. It is the responsibility of the USAID COR/AOR to keep the MEO and the BEO informed of any new information or changes in the activity that might require revision of the IEE.

http://www.epa.gov/asbestos http://chm.pops.int/

USAID Afghanistan - IHSSSP 1 15

Annex I

Environmental Mitigation and Monitoring Plan (EMMP)

Integrated Health Services & System Strengthening Program, Phase 1 (IHSSSP 1)

Environmental Mitigation and Monitoring Plan (EMMP)

The EMMP must be completed by each organization carrying out activities under the

USAID/Afghanistan Integrated Health Services & System Strengthening Program, Phase 1

(IHSSSP 1). It will include the organization’s own report plus the EMPs of any sub-awardees, to capture the entire range of activities funded by the USAID/Afghanistan IHSSSP 1 Program under the award. The USAID/Afghanistan IHSSSP 1 Program, implementing partners are responsible for ensuring that each sub-awardee completes and submits the EMP to the prime in a timely fashion. The EMPs are reviewed and approved by the COTR/AOTR and the Mission

Environmental Officer.

The EMMP consists of 3 parts:

1. The Environmental Verification Form

2. The Mitigation Plan for specific environmental threats carried out by the implementer

3. The Reporting Form

The EMMP Environmental Verification Form

This form indicates the categories of activities carried out by implementing partners (or their sub-awardees) and serves to ‘trigger’ USAID expectations of mitigation measures.

The EMMP Mitigation Plan

Implementing partners will use the Mitigation Plan to describe the specific actions they will undertake under each category of activity when screening reveals potential environmental threats as outlined in Section 3 of this IEE. In these cases, mitigation will be undertaken as described in

Section 5, Table 4 of this IEE. The Mitigation Plan also identifies the person responsible for monitoring compliance with mitigation and the indicator, method and frequency of monitoring.

The EMMP Reporting Form

This form reports on the results of applying the mitigation measures described in the Mitigation

Plan and identifies outstanding issues with respect to required conditions. In some cases, digital photos will be the best way to document mitigation and should be included in the report.

USAID Afghanistan - IHSSSP 1 16

USAID/Afghanistan IHSSSP 1

EMMP Part 1 of 3: Environmental Verification Form

Name ___________________________________

Name of Prime Implementing

Organization:______________________________

Name of Sub-awardee Organization (if this EMP is for a sub):

Geographic location of USAID-funded activities

(Province, District):_________________________

Date of

Screening:________________________________

Funding Period for this award: FY____- FY____

Current FY Resource Levels:

FY_______________

This report prepared by:

Name:_______________ Date: ____________

Date of Previous EMMP for this organization:

_________________ (if any)

Indicate which activities your organization is implementing under this funding:

Key Elements of Program/Activities Implemented Yes No

1 education, technical assistance or training programs analyses, studies, academic or research workshops and meetings;

document and information transfers;

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.);

2 Development and dissemination of improved agricultural production technologies for selected crops and livestock

3 Increased agricultural production

4 Seeds, Germplasm, Exotic Species

5 Dissemination of biotechnology products

6 Small-scale construction or rehabilitation of buildings and water & sanitation infrastructure

7 Sub-Grants

USAID Afghanistan - IHSSSP 1 17

USAID/Afghanistan IHSSSP 1

EMMP Part 2 of 3: Environmental Mitigation and Monitoring Plan

Category of

Activity

Describe specific environmental threats of your organization’s activities (based on analysis in Section 3 of the IEE)

Description of Mitigation

Measures for these activities as required in Section 5 of IEE

Who is responsible for monitoring

Monitoring

Indicator

Method

Frequency of

USAID/Afghanistan, IHSSSP 1

EMMP part 3 of 3: Reporting form

List each Mitigation Measure from column 3 in the EMP Mitigation

Plan (EMP Part 2 of 3)

Status of Mitigative Measures

List any outstanding issues relating to required conditions

Remarks

USAID Afghanistan - IHSSSP 1 18

Project Name:____________________________________

Certification

I certify the completeness and the accuracy of the mitigation and monitoring plan described above for which I am responsible and its compliance with the IEE:

Signature Date

Print Name

Organization

BELOW THIS LINE FOR USAID USE ONLY

USAID/Afghanistan, ________ Program, Clearance of EMP:

Cognizant Technical Officer: ___________________ Date: ____________

Mission Environmental Officer: ______________________ Date: ____________

As appropriate: REA, BEO [depending on nature of activity, which potentially may require an EA]

Note: if clearance is denied, comments must be provided to applicant