Att_18_Ghana_FtF_EG_IEE_120611.pdf

INITIAL ENVIRONMENTAL EXAMINATION

AND

REQUEST FOR CATEGORICAL EXCLUSION

PROGRAM/ACTIVITY DATA:

Program/Activity Number: USAID/Ghana_FTF_EE_2011_2015.doc

Country: Republic of Ghana

Program/Activity Title: USAID/Ghana Feed the Future Program SO 6: Economic Growth SO 7: Health

USG Foreign Assistance Framework:

Functional Objective 3: Investing in People Program Area 3.1: Health Program Element 3.1.9: Nutrition Program Area 3.3: Social and Economic Service and Protection of Vulnerable Populations Program Element 3.3.3: Social Assistance

Functional Objective 4: Economic Growth Program Area 4.2: Trade and Investment Program Element: 4.2.1: Trade and Investment Enabling Environment Program Element: 4.2.2: Trade and Investment Capacity Program Area 4.4: Infrastructure Program Element: 4.4.3: Transport Services Program Area 4.5: Agriculture Program Element: 4.5.1: Agricultural Enabling Environment Program Element: 4.5.2: Agriculture Sector Capacity Program Area 4.6: Private Sector Competitiveness Program Element: 4.6.1 Business Enabling Environment Program Element: 4.6.2 Private Sector Capacity Program Area 4.8: Environment Program Element: 4.8.2 Clean Productive Environment

Funding Begin: 2010 Funding End: 2015 LOP Estimated/Planning Amount: US$ 318,000,000

IEE Prepared By: Justice Odoi; Environmental Specialist & Mission Environmental Officer, USAID/Ghana (jodoi@usaid.gov)

Current Date: September 30, 2011

IEE Amendment (Y/N): N

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable) Categorical Exclusion: ___ X___ Negative Determination: ____X___ Positive Determination: __ X ___ Deferral (GMOs): ____X ___

ADDITIONAL ELEMENTS: (Place X where applicable)

CONDITIONS X PVO/NGO: X EMMP: X ERR: _X_

Private/Public Partnership: __X___ World Bank co-financing (GCAP) __X__

RELATED DOCUMENTATION:

ENVIRONMENTAL ASSESSMENTS

INITIAL ENVIRONMENTAL EXAMINATIONS

Competitiveness of Ghanaian Private Sector in World Markets Increased/SO6 (approved:

06/25/2010) (DOC) (PDF)

Agricultural Development and Value Chain Enhancement (ADVANCE) (approved: 06/25/2010) Integrated Coastal Fisheries Governance Program (ICFG) (under review) Business Sector Advocacy Challenge Fund (BUSAC) (approved: 04/06/2011) (DOC) (PDF) Support to Millennium Development Authority (MiDA) for Rehabilitation of Roads and

Irrigation Schemes (approved: 07/05/2011) (DOC) (PDF) Improved Health Status (approved: 03/25/2010) (DOC) (PDF) Protracted Relief and Recovery Operation (PPRO) (approved: 09/28/2010) (DOC) (PDF) Global Hunger and Food Security Initiative – USAID and Peace Corps Feed the Future

Participating Agency Program Agreement (PAPA) (approved: 06/08/2011) (DOC) (PDF)

PESTICIDE EVALUATION REPORT AND SAFER USE ACTION PLAN

ADVANCE (under review)

STRATEGY DOCUMENT

Ghana Food Security Strategy (Feed the Future), USG initiative

ENVIRONMENTAL AND CLIMATE CHANGE ANALYSIS

Ghana: Climate Change Vulnerability and Adaptation Assessment. A report submitted to USAID/Ghana

Ghana: Biodiversity and Tropical Forests Environmental Threats and Opportunities Assessment.

A report submitted to USAID/Ghana

Food Security and Climate Change in Drought-Sensitive Savanna Zones of Ghana. (PDF)

GENDER ANALYSIS

Ghana: Gender Assessment required for the Country Development Cooperation Strategy (CDCS).

A draft report submitted to USAID/Ghana Agricultural Development and Value Chain Enhancement: Gender Assessment

IMPLEMENTATION PLAN

Feed the Future Performance Monitoring Plan. A draft report submitted to USAID/Ghana

GHANA COMMERCIAL AGRICULTURE PROGRAM PRE-APPRAISAL

Co-financing Government of Ghana with World Bank, many associated analysis by USAID and World Bank, meaning USAID buys into World Bank financial and program management systems and oversight

Agreement between USAID/Ghana and World Bank on the Environmental and Social Safeguards applied to GCAP (under review)

LAND TENURE ANALYSIS

Land Tenure and Property Rights Issues in USAID Food Security Programming in Ghana (Link on Allnet: http://portal.usaidallnet.gov/documents/3249)

SUMMARY OF FINDINGS:

The purpose of this IEE, in accordance with 22CFR216, is to provide the first review of the reasonably foreseeable effects on the environment, as well as recommended Threshold Decisions for current and new activities under the USAID/Ghana Feed the Future (FtF) program using FY2010 – FY2015 resources to improve the livelihoods and nutritional status of households in Ghana.

Section 1 covers the purpose and scope of this IEE; Section 2 provides an overview of Ghana’s Country and Environmental Information; Section 3 provides a program description of USAID/Ghana’s FtF strategy; Section 4 provides an evaluation of the potential environmental impacts of current and anticipated agriculture and food security activities and the threshold environmental determination and mitigation measures for them; Section 5 describes environmental monitoring and compliance assurance responsibilities for USAID/Ghana’s Feed the future program. Monitoring, compliance and reporting expectations are addressed in Section 6. Finally, section 7 identifies “Climate-Smart” Agriculture measures relevant to the FtF investments.

For Feed the Future’s investment in the Ghana Commercial Agriculture Program (GCAP) in northern Ghana, USAID will co-finance the program with the World Bank, and USAID intends to buy-in to the World Bank Environmental and Social Safeguards (compliance) procedures, as well as other World Bank management and oversight systems and structures in working with the Government of Ghana, to the extent that they equal or exceed the standards of USAID’s statutory procedures and accepted good practices. USAID and World Bank are establishing an “Agreement Document on Use of World Bank Environmental and Social Safeguards in the GCAP under Co-financing by USAID.”

Recommended Environmental Determinations:

1. Categorical Exclusion: The following activities under the two foreign assistance objectives (Economic Growth and Health) to improve the livelihoods and nutritional status of households in Ghana are Categorically Excluded from initial environmental examination as no environmental impacts are expected as a result of these activities. All are excluded per the following citations from Title 22 of the Code of Federal Regulations 216 (22 CFR 216), subparagraph 2(c)(2):

(i) Activities involving education, training, technical assistance or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.);

(ii) Activities involving controlled experimentation exclusively for the purpose of research and field evaluation and carefully monitored;

(iii) Activities involving analyses, studies, academic or research workshops and meetings;

(v) Activities involving document and information transfers;

(vi) Studies, projects or programs intended to develop the capability of recipient countries and organizations to engage in development planning.

(viii) Programs involving nutrition, health care, or family planning services except to the extent designed to include activities directly affecting the environment (such as construction of facilities, water supply systems, waste water treatment, etc.);

(xi) Programs of maternal or child feeding conducted under title II of Pub. L. 480; and

(xiv) Studies, projects or programs intended to develop the capability of recipient countries and organizations to engage in development planning.

However, if any topic associated with these activities is one that inherently affects the environment, such as training in agricultural land preparation or training under Development Credit Authorities (DCAs) or Global Development Alliances (GDA) or other public/private partnerships, to enhance the capacity of finance institutions in rural lending, then such training will include information on how to minimize and/or mitigate these impacts. Examples include: instruction on land preparation that minimizes erosion and maximizes the retention of soil moisture or training for rural investment banks in screening loan portfolios of micro-finance institutions for potential negative impacts. See below provisions on Financial Intermediation, and on Corporate Environmental and Social Responsibility (CESR), and Responsible Agricultural Investment (RAI).

The following Categorical Exclusions are not foreseen to be applicable to the Ghana FtF or Economic Growth Programs: (iv) Projects in which [USAID] is a minor donor to a multi-donor ; (vi) Contributions to international, regional or national organizations by the United States which are not for the purpose of carrying out a specifically identifiable project or projects; (vii) Institution building grants to research and educational institutions in the United States such as those provided for under title XII (1979); (ix) Assistance provided under a Commodity Import Program; (x) Support for intermediate credit institutions when the objective is to assist in the capitalization of the institution or part thereof and when such support does not involve reservation of the right to review and approve individual loans made by the institution;

(xii) Food for development programs conducted by food recipient countries under title III of Pub. L. 480;

(xiii) Matching, general support and institutional support grants provided to private voluntary organizations (PVOs) to assist in financing programs where [USAID]'s objective in providing such financing does not require knowledge of or control over the details of the specific activities conducted by the Private Voluntary Organization (PVO). See Section 5.

2. Deferral

A Deferral is recommended for technology development and dissemination involving genetically modified organisms (GMOs), pending further details on if, how and which transgenic materials may be addressed by the Intervention, and more details on the biotechnology component. Prior to irreversible commitment of funds to activities potentially involving GMOs in research, field trials or dissemination, the appropriate USAID Biosafety Procedures will be addressed (ADS 201.3.6.3b and draft ADS 211). Likewise, approval will be sought as appropriate from the cognizant national biosafety authority.

All USAID-funded interventions involving biotechnologies must be subjected to a biosafety review prior to implementation.

3. Negative Threshold Determinations (22 CFR216.3 (a) (2) (iii))

3.1. Financial intermediation, micro-credit, loans, micro-finance institutions (MFIs) and micro-enterprises, loan guarantees, and Global Development Alliances (GDA) and Development Credit Authority (DCA) commitments.

Conditions:

The Mission shall ensure that the Guaranteed Party or Parties have environmental screening system sufficient to demonstrate compliance with Government of Ghana (GoG) environmental laws and to enable USAID to make an assessment of the environmental impact of such activities and shall submit to USAID their proposed policies and procedures to assure that the projects financed are environmentally sound and comply with applicable laws and procedures.

In the event a DCA or GDA is to be established, refer to guidance on the ENCAP Africa website, http://www.encapafrica.org/meoEntry.htm, Recommended and Acceptable Language and Formats

(RALF) for IEEs, and consult with the Regional Environmental Advisor (REA) and Bureau Environmental Officer (BEO). Responsible Agricultural Investment and Corporate Environmental and Social Responsibility will be promoted. See the GCAP AllNet Portal GCAP Document, Responsible Investment, at http://portal.usaidallnet.gov/documents.

3.2. Agricultural productivity technologies and inputs (e.g. fertilizers, pesticides, hybrid seeds, construction, land and water management practices, new crop commodity sub-sectors and construction) as follows:

3.2.1. Use of fertilizers

Conditions:

The FtF team shall work with activity implementing partners to ensure that only fertilizers that are approved by both the local regulatory authority and the USEPA shall be introduced and utilized. Also implementing partners must assure that potential users are trained in proper fertilizer handling, storage, use and application techniques and fertilizers are employed according to the best practices, promoting integrated soil fertility management (ISFM). Refer to Annex 3, Fertilizer Fact Sheet. USAID/Africa Bureau, also at this URL: http://www.encapafrica.org/egssaa/AFR_Fertilizer__Factsheet_Jun04.pdf.

3.2.2. Pesticides

Pursuant to 22 CFR216.3 (b) (1), a Negative Determination with conditions is recommended for activities involving use of pesticides.

Conditions:

The FtF team shall ensure that any activity involving pesticides, or new pest management products or technologies will be preceded by the preparation and BEO approval of PERSUAPs in accordance with Agency guidance, and fulfilling all analytical elements required by 22CFR216.3 (b), USAID’s Pesticide Procedures. The AFR BEO and USAID/WA Regional environmental staff will assist the Ghana Mission Environmental Officer (MEO) and FtF Activity Managers in establishing the need. New PERSUAP, if any, will be commissioned as necessary, by the respective implementing partners.

The existing ADVANCE PERSUAP will be adapted to encompass the scope of USAID/Ghana’s Commercial Agriculture and other FtF Programs in Northern Ghana. The Government of Ghana will be producing a Pest Management Plan (PMP) in accordance with the World Bank Operational Procedure

4.09. USAID’s PERSUAP will be controlling in terms of influencing the use of pesticides (USEPA-registered) and integrated pest and plant health management.

3.2.3. Seeds, seed supply, planting materials, germplasm, exotic species

Conditions:

The FtF team and activity implementing partners shall ensure that suppliers:

a) Ensure appropriateness for the agroclimatic zone to which they are being introduced;

b) Avoid introducing exotic invasive species; and

c) Avoid providing or promoting GMOs, unless the Ghana and USAID Biosafety Procedures are followed.

The Foreign Assistance Act, Part I, Section 119(g) - Endangered Species, specifies that USAID shall deny any direct or indirect assistance under this chapter for actions which significantly degrade national parks or similar protected areas or introduce exotic plants or animals into such areas.

This requires identifying and mitigating any potential direct adverse impacts on the physical environment and human health and safety (such as due to aflatoxin contamination) arising from distribution of seeds.

If biotechnology, biosafety, and genetically-modified organisms (GMOs) or life-modified organisms (LMOs) activities are to be considered in the scope of Ghana FtF activities, any support for laboratory- or field-based research, multiplication, or dissemination of GMOs or LMOs shall be subject to review under the Agency’s Biosafety procedures, and an appropriate environmental review conducted and approved in advance of commitment of funds.

3.2.4. Small scale construction

Condition:

The FtF team shall ensure rehabilitation of existing facilities and construction of facilities in which the total surface area disturbed is less than 10,000 square feet (1000 m2 ), is not done in protected areas or other environmental sensitive areas and that these activities shall be conducted following principles for environmentally sound construction, as provided in the Small Scale Construction chapter of USAID/Africa Bureau’s Environmental Guidelines for Small-scale Activities in Africa (EGSSAA):

http://www.encapafrica.org/EGSSAA/Word_English/construction.doc.

For the construction of any facilities in which the total surface area disturbed exceeds 10,000 square feet (1,000 square meters), the program shall conduct a supplemental environmental review according to guidance contained in the Environmental Review Form (ERF/ERR)on the ENCAP website “Compliance Forms” page (http://www.encapafrica.org/compliance.htm). Construction will not begin until such a review is completed and approved by the Mission Environmental Officer.

3.2.5. Activities involving land and water management improvement, watershed management, soil erosion control

Conditions:

To ensure that optimal practices are followed, pertinent chapters of the USAID EGSSAA are the following: Chapter 1- Agriculture: Soil and Water Resources, including Irrigation (http://www.encapafrica.org/EGSSAA/Word_English/agriculture.doc.

The FtF team and activity implementing partners shall ensure that improvements in land and water management techniques do not cause destruction or degradation of natural habitat, including deforestation, land degradation and drainage of wetlands; lead to loss of biodiversity; do not lead to the introduction of exotic and non-native animals and plants; lead to erosion and loss of soil fertility, siltation of water bodies or reduction in water quality; or spread disease.

3.3. Minor Irrigation Infrastructure

“Minor” rehabilitation activities are recommended for a Negative Determination with Conditions stipulating that optimal environmental design and engineering practices be applied in accordance with USAID/AFR’s EGSSAA, Chapter II.2, Agriculture and Irrigation:

http://www.encapafrica.org/EGSSAA/Word_English/agriculture.doc

See below for major irrigation works’ recommended Positive Determination (4.2 in Summary).

3.4. Minor Roads

A Negative Determination with conditions is recommended for activities involving minor feeder rural road construction and rehabilitation of old roads. Negative impacts on the environment may occur.

Rural roads development and improvement should be conducted in a manner consistent with the good planning, design and implementation practices described in EGSSAA Part II: Chapter 14: Rural roads (http://www.encapafrica.org/EGSSAA/Word_English/roads.doc).

See below for major road works’ recommended Positive Determination (4.1 in Summary).

3.5. Sub-grants

Pursuant to 22 CFR216.3(a)(2)(iii), a Negative Determination with Conditions is recommended for activities involving subawards, sub-grants and small grants programs, such as to business association, civil society and private sector partners, involving support for activities with the potential for impact on the environment, i.e. those that would not qualify for Categorical Exclusion. The EG Team, together with the MEO, is responsible for determining whether the activities intended for support warrant an environmental screening process.

Conditions:

In the event that sub-grants and small grants will support activities with the potential for impact on the environment, the Contracting and Agreement Officer Technical Representatives (COTR/AOTRs) and Activity Managers in USAID/Ghana’s FtF program has the responsibility for assuring that an environmental screening process is introduced by implementing partners. The standards to achieve for these activities are presented in USAID’s “Environmental Guidelines for Small–scale Activities in Africa” (EGSSAA), found on-line at http://www.encapafrica.org/EGSSAA, specifically Part II Sector-specific Guideline and Part III Micro and Small Enterprises.

Refer to Annex 2 for the template “Environmental Review Form (ERF/ERR) Screening Form for new activities proposed under USAID/Ghana FtF program”, which can be adapted by partners. This can be found online at http://www.encapafrica.org/documents/AFR-EnvReviewForm-20Dec2010.doc

The Contracting and Agreement Officer Technical Representatives (COTR/AOTRs) and Activity Managers in USAID/Ghana’s FtF program shall be responsible for, first, clearing the implementing partner’s category determination of sub-grant activities. Classifications of Moderate or unknown risk or higher will be referred to the Mission Environmental Officer along with any required Environmental Review Reports (ERRs). All classifications of High risk and their ERRs must be approved by the Bureau Environmental Officer (BEO).

When ERRs are necessary, implementing partners will observe recommendations in the Africa Bureau- EGSSAA for relevant sectors when developing mitigation actions and monitoring plans. Once the ERRs are approved, project implementers should ensure mitigation measures and monitoring procedures described therein are in place as they will be considered requirements.

4. Positive Threshold Determinations (22 CFR216.2 (d) (2) and 216.6)

4.1. Major road and related infrastructure construction, a Positive Determination is recommended, pursuant to 22 CFR216.2 (d) (2) and 216.6. For any USAID support for the construction of roads under this program, an Environmental Impact Assessment shall be developed before program can begin.

4.2. Major irrigation infrastructure activities -- e.g. irrigation works rehabilitation and new development, dam construction). They can have a negative impact on the physical environment.

The FtF team and activity implementing partners shall ensure that any USAID support for the construction irrigation system and of roads construction under this program, an Environmental Impact Assessment (EIA) shall be developed before program can begin.

These determinations to produce Environmental Assessments are consistent with World Bank and GoG confirmation that (1) the social and environmental safeguards policies triggered for the GCAP and

(2) the five sets of safeguard instruments that would be prepared by the GoG to ensure social and environmental impacts will be appropriately mitigated as per the World Bank’s safeguard policies. GoG will prepare five stand alone safeguards documents, namely:

an Environmental and Social Management Framework (ESMF), a Pest Management Plan (PMP);

a Resettlement Policy Framework (RPF) which will mainly apply to activities in Components 2, and 3 for the entire project. A framework approach is being adopted for the entire Ghana Commercial Agriculture Project to mitigate against impacts for project activities that will not be identified prior to project appraisal, In the Accra Plains, a well-defined but not a USAID investment area; an Environmental and Social Impact Assessment (ESIA) and a Resettlement Action Plan (RAP) will be prepared.

Further, though not strictly a Safeguards requirement, a gender assessment and land tenure and property rights assessment will be brought to bear on the design and implementation of GCAP in Northern Ghana.

5. Private Sector CESR.

Given the public/private partnership modalities expected to be emphasized, especially under GCAP, it is expected that private sector Corporate Environmental and Social Responsibility (CESR) (http://en.wikipedia.org/wiki/Corporate_social_responsibility), and Responsible Agricultural Investment (http://www.responsibleagroinvestment.org/rai/node/256) will be promoted proactively, and investor expected to support appropriate measures.

Banks - The Equator Principles (EPs) are a voluntary set of standards for determining, assessing and managing social and environmental risk in project financing. Please refer to http://www.equator-principles.com/documents/Equator_Principles.pdf for further details.

6. General Across-the-Board Conditions There are 18 sector-specific chapters in Part II of Environmental Guidelines for Small-Scale Activities in Africa, (2nd Edition) and 7 in Part III. Micro and Small Enterprises (http://www.encapafrica.org/egssaa.htm#II) which are expected to be applied across-the-board, as applicable.

In addition, there are certain requirements that apply to all activities falling under the threshold determination of “Negative Determination with Conditions” and “Positive Determination”. These include:

6.1. Environmental Compliance Language in Procurements/Solicitations The responsibility for implementing activities in accordance with the findings and conditions of this IEE must be incorporated into all contracts and grants that serve to implement activities covered under this IEE. Refer to the fact sheet “Environmental Compliance: Language for Use in Solicitations and Awards” for help in assembling appropriate, ADS-mandated environmental compliance language for all solicitations and awards1, which links to the appropriate ADS 204 Helpfile. The solicitation language will draw upon the determinations in this IEE.

6.2. Budget provisions

1 http://www.encapafrica.org/meo_resources/ECL_Factsheet%20(final).pdf.

This will be made within USAID/Ghana and/or the partners to allow for the environmental reviews and EIAs to be accomplished appropriately.

6.3. Oversight and Field Monitoring.

Contracting and Agreement Officer Technical Representatives (COTR/AOTRs) and Activity Managers in USAID/Ghana’s Food Security program, working with the MEO, will undertake field visits and consultations with implementing partners to jointly assess the environmental impacts of ongoing activities, and the effectiveness of associated mitigation and monitoring plans.

AOTRs/COTRs and Activity Managers will undertake a review of the existing PERSUAPs and determine their continued applicability and, with the USAID/WA REA and AFR BEO, establish the need for amendment or preparation of new PERSUAPs. In the event new PERSUAPs are required for new sectoral programs, then no pesticides shall be procured or used until the PERSUAP is approved by the

BEO.

Organizations receiving USAID/Ghana funds and transferring them through grants or other mechanisms to other organizations must incorporate provisions stipulating:

the completion of annual EMMRs, and that activities to be undertaken will be within the scope of the environmental determinations and recommendations of this IEE.

USAID/Ghana will ensure that implementing organizations have sufficient capacity to complete the environmental screening process and to implement monitoring and mitigation measures.

For activities that are not funded or fully funded by USAID/Ghana, but are an identifiable part of an Agriculture and Food Security program activity (for example if another source of funding is supporting agricultural activities), the implementing partner must assure that, at a minimum, the equivalent USAID standards for mitigation, as presented in Section 4, are followed.

6.4. Adherence to applicable GoG environmental laws and policies USAID has always intended to work within, complement and reinforce the host government’s environmental compliance policies and regulations. Within the 22 CFR Part 216 framework, it is A.I.D.

policy to: (1) Ensure that the environmental consequences of A.I.D.-financed activities are identified and considered by A.I.D. and the host country prior to a final decision to proceed and that appropriate environmental safeguards are adopted; (2) Assist developing countries to strengthen their capabilities to appreciate and effectively evaluate the potential environmental effects of proposed development strategies and projects, and to select, implement and manage effective environmental programs.

Since 2005, the World Bank Executive Directors approved OP and BP 4.00 proposals for Expanding the Use of Country Systems in Bank-Supported Operations. This was to pilot the use of borrower systems to address environmental and social safeguard issues and that are approved by the Board.

7. Environmental Mitigation and Monitoring Report (EMMR) Bi-lateral implementing partners under USAID/Ghana FtF program will complete an annual EMMR of all activities, using the guidance and forms in Section 5 and as explained further under “Monitoring and Reporting” in that section. Provision for completing EMMRs in October of each year should be a part of annual work plans.

USAID/Ghana FtF program’s implementing partners will use an annual Environmental Mitigation and Monitoring Report ( EMMR) to ensure programmatic compliance with 22 CFR 216 and ADS 204.5.4 by documenting that any conditions applicable under this IEE have been met for relevant activities carried out under bi-lateral awards.

EMMRs will be reviewed and approved by the COTR/AOTR and the Mission Environmental Officer.

The EMMR consists of 3 parts, the:

1. Environmental Verification Form

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

3. Reporting Form

EMMR, Environmental Verification Form. Because of the integrated nature of the USAID/Ghana’s FtF program, a single bi-lateral award (along with any sub-awards) might contain activities with various conditions required for prevention or mitigation of environmental impacts. This form indicates the categories of activities carried out by implementing partners (or their sub-awardees).

EMMR, Mitigation Plan. The Mitigation Plan describes specific actions that will be undertaken under each category of activity when screening reveals potential environmental threats as outlined in Section 4 of this IEE. In these cases, mitigation will be undertaken as described in Section 4. Also, it identifies the person responsible for monitoring compliance with mitigation and the indicator, method and frequency of monitoring.

EMMR, 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.

As laid out in ADS 204.5.4, USAID/Ghana is responsible for the monitoring and evaluation of the environmental effects of all ongoing and proposed program development activities, so as to ensure they remain as Categorical Exclusions or within the bounds of the Negative Determinations with Conditions, and the Positive Determinations. The process of environmental monitoring and evaluation will be integrated into the Agriculture and Food Security Team's Performance Monitoring and Evaluation Plan.

Annexes:

Annex 1: Environmental Mitigation and Monitoring Plan and Report (EMMR) Template. Also available at URL: Recommended template for EMMPs http://www.encapafrica.org/meo_resources/EMMP%20Templat%209May08.doc

Annex 2: Environmental Screening Form for New Activities Proposed under USAID/Ghana FtF/EG programs: , as last revised in Dec. 2010. Also available at:

http://www.encapafrica.org/documents/AFR-EnvReviewForm-20Dec2010.doc

Annex 3: Fertilizer Fact Sheet. USAID/Africa Bureau. Also at http://www.encapafrica.org/egssaa/AFR_Fertilizer__Factsheet_Jun04.pdf.

Annex 4: Illustrative Options for Integrating NRM/CC/Water Considerations into Bilateral Mission Feed the Future Programs

APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:

CLEARANCE:

USAID/Ghana Mission Director: _____ Date:

Cheryl Anderson

CONCURRENCE:

Bureau Environmental Officer: ___________________________________ Date:_____ Brian Hirsch

File No: USAID/Ghana_FTF_IEE_2011_2015.doc

Mission Environmental Officer: ______________________ Date: _____________ Justice Odoi

Senior Food Security Officer: ______________________ Date: _____________ Fenton Sands

SO6 Team Leader: Date :

Nino Nadiradze

SO7 Team Leader: Date :

Laurel Fain

Supervisory Program Officer: ______________________ Date: _____________ Daniel Sanchez-Bustamante

Sr. Regional Env. Policy Advisor: Date:9/15/2011 (USAID/AFR/SD): Walter Knausenberger

OPTIONAL CLEARANCES

Regional Legal Advisor: ______________________ Date: _____________

INITIAL ENVIRONMENTAL EXAMINATION

AND

CATEGORICAL EXCLUSION

USAID/GHANA FEED THE FUTURE

Contents

1.0 PURPOSE AND SCOPE OF THIS INITIAL ENVIRONMENTAL EXAMINATION (IEE)

2.0 COUNTRY ENVIRONMENTAL INFORMATION

3.0 USAID/GHANA FEED THE FUTURE OBJECTIVE AND PROGRAM STRUCTURE

4.0 EVALUATION OF PROGRAM ISSUES WITH RESPECT TO ENVIRONMENTAL IMPACTS

5.0 RECOMMENDED THRESHOLD DETERMINATIONS AND MITIGATION MEASURES

6.0 MONITORING, COMPLIANCE ASSURANCE AND REPORTING

7.0 CLIMATE-SMART AGRICULTURE

8. REFERENCES

List of Annexes

Annex 1. Environmental Mitigation and Monitoring Report (EMMR) Template

Annex 2: Environmental Screening Form for New Activities Proposed under USAID/Ghana FtF/EG programs:

Annex 3. Fertilizer Fact Sheet. USAID/Africa Bureau.

Annex 4: Illustrative Options for Integrating NRM/CC/Water Considerations into Bilateral Mission Feed the

Future Programs

List of Figures

Figure 1. Map of Ghana (West Africa)

Figure 2. Map of agro-ecological zones

Figure 3. Map of water resources in Ghana

Figure 4. Geographic focus for Feed the Future investments

Figure 5. Effect of climate change on soil and water resources

List of Tables

Table 1. Ghana Country Profile

Table 2. Policies relevant to the FtF investments

Table 3. Poverty incidence by administrative region, 1991/92 and 1998/99

Table 4. Anticipated impacts of climate change and human threats on agriculture and food security

Table 5. Recommended Threshold Determinations for Improve Resiliency in Northern Ghana (RING)

Table 6. Recommended Threshold Determinations for existing programs under the Improved Competitiveness of

Major Food Value Chains

Table 7. Recommended Threshold Determinations for planned programs under the Improved Competitiveness of

Major Food Value Chains

Table 8. Threshold Determinations for each activity group under USAID/Ghana support to GCAP: Negative and

Positive Determinations

Table 9. General Requirements that apply to all activities falling under the threshold determination of “Negative

Determination with Conditions”

List of Abbreviations

ADVANCE Agricultural Development and Value Chain Enhancement AFR Africa AgSWAp Agriculture Sector, Sector-Wide Approach AOTR Agreement Officer Technical Representatives BEO Bureau Environmental Officer BFS Bureau of Food Security BUSAC Business Sector Advocacy Challenge Fund CESR Corporate Environmental and Social Responsibility COTR Contracting Officer Technical Representatives DCA Development Credit Authority DRLRLU Diagnostic Review of Land Rights and Land Uses EGSSAA Environmental Guidelines for Small Scale Activities in Africa EIA Environmental Impact Assessment ENCAP Environmentally Sound Design and Management Capacity-building for

Partners and Programs in Africa ERF Environmental Review Form ERR Environmental Review Report ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework FtF Feed the Future GAIDA Ghana Agricultural Input Dealers Association GCAP Ghana Commercial Agriculture Program GDA Global Development Alliances GMO Genetically Modified Organisms GSS Ghana Statistical Services GSSP Ghana Strategy Support Program ICFG Integrated Coastal and Fisheries Governance IEE Initial Environmental Examination IFPRI International Food Policy Research Institute IDA International Development Association IR Intermediate Results ISFM Integrated Soil Fertility Management METSS Monitoring, Evaluation, and Technical Support Services MFIs Micro-Finance Institutions MiDA Ghana Millennium Development Authority MoFA Ministry of Food and Agriculture MoFEP Finance and Economic Planning MoTI Ministry of Trade and Industry PAPA Participating Agency Program Agreement PASA Participating Agency Service Agreement PERSUAP Pesticide Evaluation Report and Safer Use Action Plan PMP Pest Management Plan PPP Private-Public Partnerships RAI Responsible Agricultural Investment RALF Recommended and Acceptable Language and Formats RAP Resettlement Action Plan REA Regional Environmental Advisor RPF Resettlement Policy Framework SADA Savannah Agricultural Development Authority USDA United States Department of Agriculture USEPA United States Environmental Protection Agency WA West Africa WB World Bank WIAD Women in Agriculture Development

1. PURPOSE AND SCOPE OF THIS INITIAL ENVIRONMENTAL EXAMINATION (IEE)

The purpose of this IEE, in accordance with 22CFR216, is to provide the first review of the reasonably foreseeable effects on the environment, as well as recommended Threshold Decisions for current, new and potentially to be designed activities under the USAID/Ghana Feed the Future (FtF) program using FY2010 – FY2015 resources to improve the livelihoods and nutritional status of households in Ghana. A series of subsidiary IEEs and Request for Categorical Exclusions are in place and being applied, or will be put in place as necessary. USAID/Ghana will participate with the World Bank in the implementation support and oversight for the Ghana Commercial Agriculture Program, co-financed with the World Bank and implemented by the Government of Ghana, contracted partners and the private sector.

2. COUNTRY ENVIRONMENTAL INFORMATION

Ghana is a West African state located between Longitude 1.5º E and 3.5ºW; and Latitude 4º N and 11º. It shares international borders with Burkina Faso to the North, Togo to the East, La Cote d’Ivoire to the West and the Atlantic Ocean to the South. Administratively, the country is divided into 10 regions (Fig.1) and 170 districts with Accra as the capital. The country is ecologically diverse with vegetation types that range from savanna to wet evergreen forests. A summary profile for Ghana outlined below (Table 1).

Figure 1. Map of Ghana (West Africa) Source: Justice Odoi

Table 1. Ghana Country Profile

Geography and Environment Total surface area:

Coastline:

Natural resources:

Agriculture Land Area Area under cultivation Total area under irrigation Area not under cultivation Area under inland waters

238,540 sq km 565 km Gold, timber, industrial diamonds, bauxite, diamond, manganese, fish, rubber, hydropower, salt.

13,628,179 Hectares (Ha) (2010) 7,846,551Ha (2010) 30,269 Ha (2010) 5,781,628 Ha (2010) 1,100,000 Ha (2010)

Population Population:

Population growth rate:

Life expectancy: total population:

Urban population (% of total):

Urban population annual growth rate:

24, 223,431 (Ghana Statistical Service, 2011) 1.8% (2000 population)

59.85 years (2009 est)

46.3 (2005 population) 4.15% (1995-2015)

Economy

GDP:

GDP - real growth rate:

GDP per capita: purchasing power parity GDP composition by sector:

agriculture, forestry and fisheries:

industry:

services:

Population below poverty line:

Labor force:

Labor force - by occupation:

Unemployment rate:

Industries:

Industrial production growth rate:

Industries located in coastal zone:

Electricity - production:

Electricity - production by source:

Electricity - consumption:

Electricity - exports:

Electricity - imports:

Agriculture - products:

Exports:

US$16.654 billion (2008 est.)

6.2% (2008 est)

US$739 (2008 est.)

36% 25% (including 15% from manufacturing) 31.4% (2000 est.)

11.5 million (2008 est.)

9 million (2000 est.)

agriculture 56% (including 3% in fisheries), industry 16.2%, services 5.9%, sales & clerical 19.3%, Professional 8.9% (1999 est.)

20.3% (2001 est.)

mining, lumbering, light manufacturing, aluminium smelting, food processing 4.2% (1996 est.)

70%

5.466 billion kWh (1999) fossil fuel: 26.82% hydro: 73.18%

5.573 billion kWh (1999) 400 million kWh (1999) 890 million kWh (1999) cocoa, rice, coffee, cassava (tapioca), peanuts, corn, shea nuts, bananas; timber US$1.6 billion (f.o.b., 2000)

Exports - commodities:

Imports:

Imports - commodities:

Currency code:

Exchange rate:

gold, cocoa, timber, tuna, bauxite, aluminium, manganese ore, diamonds US$2.2 billion (f.o.b., 2000) capital equipment, petroleum, foodstuffs Cedi (GHC) Cedis per US dollar – 1.50 (December 2010)

Water Resources and Uses Internal flows Flows from other countries Total resources per capita cu. m3:

Annual freshwater withdrawals:

% of total renewable resources:

% for agriculture:

% for industry:

% for domestic:

30 billion cu. m. 1999

22.9 billion cu. m. 1999:

2,832

0.3 billion cu. m 0.6

Adapted from the ICFG IEE

2.1. Environmental baseline

Agro-ecological zones Characteristics Ghana is ecologically diverse, supporting two major biomes: tropical high forest and savannah, which are further divided into six agro-ecological zones on the basis of climatic conditions, geology, and soil. The agro-ecological zones from north to south are: Sudan savanna, Guinea savanna, Forest-savanna transition, Deciduous forest, Rain forest, and the Coastal savanna zones (Fig. 2).

The forest zone covers roughly one third and the drought-sensitive savanna areas cover two-thirds (about 40 percent) of the total land area of Ghana. Rainfall significantly varies between these zones, with the forest areas experiencing bi-modal rainfall ranging between 1,300 and 2,100 mm and the savanna experiencing mono-modal rainfall ranging between 800 and 1200 mm per annum.

Most soils in Ghana are old and classified as Lixisols, Acrisols, Nitisols, Luvisols, Lithosols, Plinthosols, Gleysols and Cambisols. Alluvial soils (Fluvisols) and eroded shallow soils (Leptosols) are found in all the ecological zones. The soils found in the lowland evergreen forests are mainly forest oxysols (or Oxisol in the USDA soil classification system) or forest Oxysol-ochrosol integrade. The principal soils which cover nearly the whole area of moist semi-deciduous (MSD) forests are the forest Ochrosols (mainly Ultisols in the USDA system). They differ from the forest Oxysols by being slightly alkaline in nature, richer in nutrients and not highly leached. They support many tree crops including cocoa citrus and coffee. The most extensive soils in the northern savannas are the groundwater lateritic soils developed over the Voltaian shales and granites (Menczer and Quaye, 2006).

Water resources Northern Ghana is drained by the Black and White Volta Rivers, which join to form the Volta, which then flows south to the sea. The two major tributaries of the Volta are the Oti and Afram Rivers.

Together, the rivers drain the Volta Basin. The Volta finally enters the Gulf of Guinea at Ada in southeastern Ghana. The South-Western Rivers System comprises the Bia, Tano, Ankobra and Pra Rivers, while the Coastal Rivers System is made up of Ochi-Amissah, Ochi-Nakwa, Ayensu, Densu and Tordzie/Aka Rivers. The Volta River basin is shared with Cote d’Ivoire, Burkina Faso, Togo, Benin and Mali. The Bia is shared with Cote d’Ivoire, while the lower reaches of the Tano River also form part of the boundary with Cote d’Ivoire. The Volta River and Lake provide water for industrial and domestic use, irrigation as well as livelihoods for a number of people who are engaged in fishing along its banks and remains an important transportation link between southern and northern Ghana. The quality of freshwater in these three major systems is generally good for multipurpose use. Figure 3 shows the water resources in Ghana.

Land degradation and desertification Land degradation is geographically widespread in all areas of the country and can be attributed to physical (in the form of soil erosion, compaction, crusting, and iron-pan formation), chemical (depletion of nutrients, salinity, and acidification), and biological (loss of organic matter) processes. Soil erosion is the primary form of land degradation in Ghana (EPA 2002). The main forms of soil erosion in Ghana are sheet erosion through surface runoff, rill erosion in permanent and shifting microchannels, and gully erosion in permanent channels (EPA 2002). The estimated percentage of total land area of Ghana prone to desertification is 35 percent (about 83,489 km2) with the Upper East and eastern part of Northern Region (78,718 km2) or 33 percent of the total land area of the country) facing the greatest hazard.

Figure 2. Map of agro-ecological zones; source: RESPTA (https://www.uni-hohenheim.de/respta/climate.php)

Figure 3. Map of water resources in Ghana; Source; Justice Odoi

2.2. Environmental Policies and Procedures

Main national policies relevant to the FtF investments are outlined in Table 2.

Table 2. Policies relevant to the FtF investments

Policies Objectives Relevant to FtF Program

National Environmental Policy (NEP), 1992, 2010

(PDF)

The first National Environmental Policy was adopted in 1992 to provide the broad framework for the implementation of the National Environmental Action Plan. The 1992 Policy Identified a restructured lead agency (The Environmental Protection Agency, EPA) to drive the process towards sustainable development. It sought to ensure reconciliation between economic development and natural resource conservation, to make a high quality environment a key element supporting the country’s economic and social development.

In 2010, a new National Environmental Policy was developed to reflect challenges confronting environmental management as well as to effectively ensure enforcement. . The new policy attempts to restructure and redirect the implementation strategy to achieve desired results.

EPA Act 1994 (Act 490)

It grants the Ghana Environmental Protection Agency enforcement and standards-setting powers and to ensure compliance with such

Policies Objectives Relevant to FtF Program (PDF) standards and guidelines. It also gives it the mandate to co-manage, protect and enhance the country’s environment, in particular, as well as seek common solutions to global environmental problems.

Environmental Assessment Regulation 1999 (LI 1652) (PDF) and Environmental Assessment (Amendment) Regulations, 2002 (LI 1703)

(PDF)

Provides guidance and ensure adequate consideration of biodiversity and related sensitive resources for Environmental Impact Assessments in Ghana. It combines both an environmental assessment and environmental management systems.

Water Resources Commission (WRC) Act 522, 1996 (PDF)

Provides for the preparation of comprehensive plans for the regulation, utilization, conservation, development and improvement of water resources and develops policy framework for water resources management in the country. This Act also grants rights to exploit water resources

National Water Policy (PDF)

Provides a framework for the development of Ghana’s water resources. The aim is to “achieve sustainable development, management and use of Ghana’s water resources to improve health and livelihoods, reduce vulnerability while assuring good governance for present and future generations”.

National Land Policy (PDF)

Seeks to protect a variety of habitat types, and states that all lands declared as forest reserves, strict game reserves, national parks, wildlife reserves, and similar land categories are fully protected for ecosystem maintenance and biodiversity conservation.

Fisheries Act 625, 2002

(PDF)

Seeks to establish priorities for the utilization of fishery resources and ensure the proper conservation of the fishery resources through the prevention of overfishing by:

Minimize fishery gear conflict among users as well as ensure the monitoring, control and surveillance of the fishery waters;

Promoting co-operation among local fishermen and advice on development of artisanal fishing;

Correlating fisheries with other water uses and environmental protection particularly with respect to the fish resources and food chain in the rivers, lagoons, lakes and the continental shelf along the coast of the country;

Supporting District Assemblies and fishing communities to ensure the enforcement of the fishery laws including bye-laws made by the relevant District Assemblies.

Pesticides Control and Management Act 1996 (Act

528) (PDF)

Seeks to regulate the use and management of pesticide, insecticide, weedicide, herbicide and other related chemicals in Ghana. The Act makes the EPA of Ghana the lead agency responsible for a comprehensive pesticides regulatory program. In that capacity, the EPA has the sole authority and responsibility to register all pesticides imported, manufactured, distributed, advertised, sold or used in Ghana.

National Development Planning Act, 1994 Act 479

This Act ensures the effective implementation of approved national development plans and strategies and coordinates economic and social activities country wide in a manner that will ensure

Policies Objectives Relevant to FtF Program accelerated and sustainable development of the country and improvement in the standard of living for all Ghanaians

National Action Plan to Combat Drought and Desertification (PDF)

The objective is to emphasize environmentally sound and sustainable integrated local development programs for drought prone semi-arid and arid areas, based on participatory mechanisms, an integration of strategies for poverty alleviation and other sector programs including forestry, agriculture, health, industry and water supply into efforts to combat the effects of drought.

Local Government Act 1993, Act 462, Act 2003, Act 656

(PDF)

It enjoins the District Assemblies to be responsible for the development, improvement and maintenance of human settlements and environment in the district and local levels

Biosafety Law 2011 The Ghanaian Parliament has approved a Biosafety Bill which creates a favorable enabling environment for the development and commercialization of biotech seeds and crops in Ghana. Ghana’s biosafety legislation is considered user friendly, in that it does not contain any labeling requirements for biotech or genetically modified food products, or strict liability provisions (instead adopting a simple negligence standard of liability for biotech products). Observers believe the bill will shortly be signed by the President, paving the way for a number of biotech seeds or crops to be developed for the Ghanaian market over the next few years, including biotech varieties of cotton, sweet potato, cowpea, corn, soy, and rice. The successful conclusion to the years-long effort to establish enabling legislation for agricultural biotechnology in Ghana was thanks in part to USG techical assistance and outreach efforts, and should help the country respond to the challenges of food security and climate change . USAID/Ghana will explore opportunities to partner with international agricultural research organizations, Ghanaian agricultural research institutions and/or other public and private organizations to help build an enabling environment that facilitates biotechnology development and transfer.

2.3. Background

Economic growth and agriculture Impressive growth and record poverty reduction over the past twenty years have made Ghana an African success story. Agricultural growth has played an important role in this impressive development and broad agreement among policy makers and researchers exists that the sector needs to continue to play an important role in Ghana’s future development. Analysis of the recent past yields a potential average annual total GDP growth rate of 4.9 percent between 2006 and 2015.