Attachment_14_-_Initial_Environmental_Examination_-_Modification.pdf

~T~!_~Q I MOZAMBIQUE

INITIAL ENVIRONMENTAL EXAMINATION

AMENDMENT

APPROVAL DOCUMENT

PROGRAM/ACTIVITY DATA:

Program/Activity Number:

Program Activity Title:

Country/Region:

Functional Objective:

Program Areas:

Program Elements:

AID-OAA-M-11-00021

Agriculture, Environment and Business (AEB) Portfolio Mozambique Economic Growth

4.5 Agriculture

4.6 Private Sector Competitiveness

4.8 Environment

4.5 . l Agriculture Enabling Environment

4.5.2 Agriculture Sector Capacity

4.6 .1 Business Enabling Environment

4.8.1 Natural Resources and Biodiversity

4.8.2 Clean Productive Environment

Funding Began: 2012 I Funding Ends: 2018 Total Estimated Amount: $284.5 Million

Program Components Approx. LOP

Start Date End Date funding

Coastal City Adaptation Program (CCAP) $18 million 12/01 /2012 12/01 /2018

Biodiversity and Tourism (BIOTOUR) Program $14.5 million 12/01/2012 12/0112018

US Global Food Security Presidential Initiative "Feed the $210 million 11 /20/2012 09/30/2018

Future" (FTF) Policy Reform Program $42 million FY 16 FY 20

IEE Prepared By: Eduardo Langa, Mission Environment Officer

IEE Amendment: Yes _y__ No Agriculture, Trade, and Business (ATB) Portfolio IEE - http://gemini.info .usaid .gov/egat/envcomp/document.php

Date of Original IEE: July 2012

IEE Expiration Date: 30 September 2018

Other Relevant Environmental Compliance Documents:

• 2009 AEB Pesticide Evaluation Report and Safer Use Action Plan (PERS UAP) - Implementation Form, recently extended to May 1, 2016 - http://gemini.info.usaid.gov/egat/envcomp/document.php

• Coastal City Adaptation Project IEE 2015 - http://gemini.info.usaid.gov/egat/envcomp/document.php

• USAID AgriFUTURO Program: Scaling Up Rhizobium Inoculants for Soybeans IEE Amendment 2015 -http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/42476.pdf

• DCA Loan Portfolio Guarantees (LPG) for Agribusiness Enterprises Amendment Nov 2014 - Dec 2015

African Women in Agricultural Research and Development (A WARD) and Borlaug Higher Education Agricultural Research and Development (BHEARO) Sep 2011 - Sep 2015

USAID Mozambique AEB IEE I Page 1167

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)

Categorical Exclusion: ~ Negative Determination: ~ Positive Determination: D Negative Determination with conditions: ~ Deferral: ~

ADDITIONAL ELEMENTS: (Place X where applicable) CONDITIONS x PVO/NGO: x EMMP x - - - - - - - - -

PURPOSE AND SCOPE OF THE IEE:

On September 71 ", 2012 the Bureau Environment Officer approved the Initial Environmental Examination (IEE) for the USAID/Mozambique's Agriculture, Trade, and Business portfolio. This IEE Amendment covers a variety of program changes, including an extension in time, increase in project cost estimate, and the addition of the following activities: water, hygiene and sanitation programming (WASH) under the Feed The Future (FTF) program; small-scale construction, fire management, road and airstrip maintenance, landscape planning, small-scale sustainable natural resource management livelihoods, maintenance of a mechanics shop, human-wildlife conflict management, under the Ecosystem Conservation Systems, Markets, and Tourism (ECOSMART) program implemented by Wildlife Conservation Society (WCS) ; and climate change adaptation and coastal conservation under the BIOTOUR program. In light of the extent of the changes, the original IEE has been revised and this amendment replaces it entirely. A summary of the lEE is presented below and the IEE itself is attached.

The specific purpose of this amendment is to:

• Change the name of the IEE from Agriculture, Trade, and Business (ATB) to Agriculture, Environment, and Business (AEB) to reflect new policy and programming;

• Extend the existing IEE until September 301 " , 2018 in line with the approved PAD;

• Extend the Feed The Future component end date (from the current FY 15 to FY 18), in line with the approved

PAD;

• Extend the FTF component LOP funding for the additional time between FY 15 to FY 18 from the amount of $93.5 million to $210 million as per the approved PAD;

• Update names and descriptions of FTF activities that started since the original IEE was approved;

• Add water, hygiene, and sanitation activities (including small scale water and sanitation infrastructure). This activity is foreseen under the scope of SAFRA but not covered in the existing AEB IEE;

• Add use of inoculants (an IEE amendment and a resulting EMMP to cover the safe use of inoculants has been recently prepared);

• Additional scope of activities under the BIOTOUR program to allow the mission to fund rehabilitation/upgrade of small-scale wildlife conservation infrastructures (hard engineering), fire management and early-burning techniques, road and airstrip maintenance, landscape economic land-use planning, small-scale sustainable natural resource management livelihoods such as beekeeping, maintenance of auto-mechanics shop, climate change adaptation, human-wildlife conflict management techniques, and coastal conservation;

• Add Policy Reform Program with LOP funding of$42 million and description of activities.

The Mission has several other relevant IEEs; they are listed above under Other Relevant Environmental Compliance Documents.

This IEE amendment, in accordance with 22CFR216, addresses current and proposed activities ofthe USAID/Mozambique Agriculture, Environment, and Business (AEB) within the framework of the Country Development Cooperation Strategy for Mozambique 2014-2018.

USA/O Mozambique AEB IEE I Page 2167

Intervention Categories. For the purpose of environmental review, current and anticipated activities in the AEB portfolio are grouped into the following intervention categories.

I. Government Capacity Support and Development in the Areas of Agriculture, Agribusiness, Nutrition, Climate Adaptation, Biodiversity-Based Tourism, Trade, and Energy (newly added areas);

2. Agricultural Productivity and Agribusiness Sector Competitiveness and Financing in Select Provinces;

3. Agricultural Research, Experimentation, and Related Capacity-Building;

4. Nutrition Improvement Activities, excluding Infrastructure;

5. Construction, Rehabilitation and/or Operation of Small Scale Agricultural Infrastructure;

6. Climate Adaptation Activities for Select Coastal Cities;

7. Biodiversity-Based Tourism Development (small-scale construction, fire management, road and airstrip maintenance, landscape planning, small-scale sustainable natural resource management livelihoods, maintenance of a mechanics shop, human-wildlife conflict management, and coastal conservation added);

8. Small Grants Activities; and,

9. Water, Hygiene and Sanitation (newly added activity)

This IEE provides a brief statement of the factual basis for a Threshold Decision as to whether an Environmental Assessment or an Environmental Impact Statement is required for the activities managed under this program. A summary of general project implementation and monitoring is also presented.

Recommended Determinations

The following table summarizes the recommended determinations associated with the AEB portfolio intervention categories listed above. Details of activity descriptions, analysis of potential environmental impacts, and activity-by activity determinations and conditions are presented in the attached IEE.

Intervention Category Categorical Negative Deferral Exclusion(s) Determina tion(s)

Government Capacity Support and Development in the Areas of

Agriculture, Agribusiness, Nutrition, Climate Change (w/ conditions) (see Adaptation, Biodiversity-Based Tourism, Trade, and Energy Section 3.2 of IEE)

Agricultural Productivity and Agribusiness Sector ,/

Competitiveness and Financing in Select Provinces (w/ conditions)

Agricultural Research, Experimentation and Related Capacity- ,/ ,/

Building (w! conditions)

Nutrition Improvement Activities, excluding Infrastructure ,/ ,/

(w/ conditions)

USAID Mozambique AEB IEE I Page 3167

Construction/Rehab of Small Scale Agricultural Infrastructure ,/

(w/ conditions)

Climate Adaptation Activities for Select Coastal Cities ,/ ,/

(w/ conditions)

Biodiversity-Based Tourism Development ,/ ,/

(w/ & w/out conditions)

Water, Hygiene and Sanitation (newly added activity) ,/

(w/ conditions)

Note that Negative Determinations are recommended pursuant to 22 CFR 216.3(a)(2)(iii).

Deferrals of a Threshold Determination apply to:

(see Section 3.6 of IEE)

(see Section 3.8 of IEE)

• Development of detailed statute or implementing regulations for nutrient fortification (under Government Capacity Support and Development in the Areas of Agriculture, Agribusiness, Nutrition, Climate Adaptation, and Biodiversity-Based Tourism), (Section 3.2 of IEE);

• Expanding the use of USA ID Development Credit Authority (DCA) facility for financing tourism enterprises (under Biodiversity-Based Tourism Development), (Section 3.8 of IEE); and,

• Irrigation Schemes of >50Ha irrigated areas, (Section 3 .6 of IEE)

These deferrals must be resolved in a new or amended IEE prior to obligation of funds for implementation of the activities identified.

General Restrictions (reproduced verbatim from section 4.1 of the IEE)

1. GMOs/LMOs: For purposes of compliance with USAID procedures, Genetically Modified Organisms (GMOs) or Living Modified Organisms (LMOs) are defined as "living organisms modified by genetic engineering techniques" and include, e.g., plants, microorganisms, live animal vaccines (if used outside a contained area and not approved in the US), animals, and insects.

This IEE does not authorize support for laboratory- or field-based research involving GMOs/LMOs, nor does it authorize support for multiplication, confined field testing, open release, or commercialization of GMOs/LMOs. Support for laboratory research involving GMOs/LMOs in contained facilities would require an approved amendment to this IEE. Support for field testing or open release ofGMOs/LMOs would require successful review under USAID's Biosafety Procedures followed by an approved IEE amendment.

Mozambican national requirements must be met in either case.

See the ENCAP Biosafety Procedures Factsheet for more information:

www.encapafrica.org/meo resources/Biosafety 5Feb20 I O.pdf.

2. PESTICIDES. All activities that fall outside of the category of controlled experimentation exclusively for the purpose ofresearch and field evaluation and entail the procurement or use, or both, of pesticides shall conform

USAID Mozambique AEB IEE I Page 4167 with the 2009 AEB Pesticide Evaluation Report and Safer Use Action Plan, conducted in accordance with USA ID Pesticide Procedures (22 CFR 216.3(b )). No funds shall be obligated or expended for the procurement or use of pesticides unless they are specifically approved in the AEB Agriculture PERSUAP developed in 2009.

General Project Implementation and Monitoring Requirements (reproduced verbatim from Section 4.2 of the IEE)

In addition to the specific conditions enumerated in Section 3 of the IEE, the negative determinations recommended are contingent on full implementation of the following general monitoring and implementation requirements:

I. Consideration of Project-level IEEs. This AEB portfolio IEE was developed, as required by USA ID project design guidance, during the pre-PAD analysis stage in the project design cycle. As such, it was developed with only relatively general information available regarding proposed activities.

Therefore, for each major AEB procurement, the AEB team, in consultation with the MEO and REO, must consider whether the goal of environmentally sound design and management and clarity and transparency regarding IP and AEB team compliance requirements would be best served by development of a project-level IEE based on far more specific activity descriptions. Such project-level lEEs would supersede this portfolio IEE for a particular procurement, but would be guided by and establish conditions no less stringent than those set out by this IEE. Such lEEs must incorporate all of the remaining conditions set out in this section.

2. IP Briefings on Environmental Compliance Responsibilities. The AEB team shall provide each AEB Implementing Partner (hereinafter IP), with a copy of this IEE. Each IP shall be briefed on their environmental compliance responsibilities by their Contracts or Agreements Officer Representative (C/AOR). During this briefing, the IEE conditions applicable to the IP's activities will be identified.

3. Development of Environmental Monitoring and Mitigation Plan (EMMP). Each IP whose activities are subject to one or more conditions set out in section 3 of this IEE shall develop and provide for C/AOR review and approval an EMMP documenting how their project will implement and verify all IEE conditions that apply to their activities.

These EMMPs shall identify how the IP shall assure that IEE conditions that apply to activities supported under subcontracts and sub grants are implemented. (In the case of large sub grants or subcontracts, the IP may elect to require the sub grantee/subcontractor to develop their own EMMP.)

(Note: refer to the AFR EMMP Factsheet, available at:

http://www.usaidgems.org/W orkshops/MalawiMay20 l 3Materials/Chapters/STEMM P. pdf)

4. Integration and implementation of EMMP. Each IP shall integrate their EMMP into their project work plan and budgets, implement the EMMP, and report on its implementation as an element ofregular project performance reporting.

!Ps shall assure that sub-contractors and sub-grantees integrate implementation of IEE conditions, where applicable, into their own project work plans and budgets and report on their implementation as an element of sub-contract or grant performance reporting.

5. Integration of compliance responsibilities in prime and sub-contracts and grant agreements.

a. Use of ADS Tool: "Environmental Compliance: Language for Solicitations and Awards, " The AEB team shall assure that all solicitation and award documents include environmental compliance language generated by the ADS Help Document/Tool: Environmental Compliance: Language for Solicitations and A wards. (http:/ !transition. usaid.gov /po licy/ads/200/204sac.pdD

USAID Mozambique AEB IEE I Page 5167

Award language generated by this document requires not simply compliance with IEE conditions, but the budgeting and planning tasks necessary for compliance, such development of EMMPs and annual review of work plans against the scope of approved Reg. 216 documentation.

b. IPs shall assure that sub-contracts and sub-grant agreements reference and require compliance with relevant elements of IEE and EA conditions.

6. Assurance of sub-grantee and sub-contractor capacity and compliance. IPs shall assure that sub-grantees and subcontractors have the capability to implement the relevant requirements of this IEE. The IP shall , as and if appropriate, provide training to sub grantees and subcontractors in their environmental compliance responsibilities and in environmentally sound design and management (ESDM) of their activities.

7. AEB Team monitoring responsibility. As required by ADS 204.5.4, the AEB team will actively monitor and evaluate whether the conditions of this IEE are being implemented effectively and whether there are new or unforeseen consequences arising during implementation that were not identified and reviewed in this IEE. The

Deputy MEO based in the Program Office will also conduct ad hoc site visits to monitor compliance. If new or unforeseen consequences arise during implementation, the team will suspend the activity and initiate appropriate, further review in accordance with 22 CFR 216 . USA ID Monitoring shall include regular site visits.

8. Use ofGDAs as Implementation Mechanisms. Where GDAs may be used as implementation mechanisms for any AEB activity and this activity has received a negative determination with conditions in this IEE:

a. AEB shall assure that applicable conditions of this IEE are applied to all USA ID-funded and pool-funded activities. This shall include writing these conditions into the GOA agreement, and into in all contracts, grants, cooperative agreements and collaborative agreements whereby USAID-funded and pool-funded activities are implemented.

b. AEB shall undertake, document, and fully take into account the results of the due diligence investigation required for prospective GDAs. (See the EN CAP GOA Factsheet:

http://www.encapafrica.org/meo _resources/Cadmus%20GDA _ factsheet_ l 9Dec06final%20draft.doc.)

9. New or modified activities. As part of its initial Work Plan, and all Annual Work Plans thereafter, lPs, in collaboration with their C/AOR, shall review all planned and on-going activities to determine if they are within the scope of this IEE.

If any IP activities are planned that would be outside the scope of this IEE, an amendment to this IEE addressing these activities shall be prepared for USA ID review and approval. No such new activities shall be undertaken prior to formal approval of this amendment.

Any ongoing activities found to be outside the scope of the approved Regulation 216 environmental documentation shall be halted until an amendment to the documentation is submitted and written approval is received from USAID. This includes activities that were previously within the scope of the IEE, but were substantively modified in such a way that they move outside the scope.

10. Compliance with Host Country Requirements. Nothing in this IEE substitutes for or supersedes IP, sub grantee and subcontractor responsibility for compliance with all applicable host country laws and regulations.

The IP, sub grantees, and subcontractor must comply with host country environmental regulations unless otherwise directed in writing by USAID. However, in case of conflict between host country and USA ID regulations, the latter shall govern.

USAID Mozambique AEB IEE I Page 6167

11. Government to Government (G2G) assistance. Where activities are carried out via direct funding of governmental partners and this is not noted in the IEE activity description, AEB will nonetheless assure, via negotiated implementation arrangements with the governmental partner and, potentially, complementary environmental monitoring and management support activities, that the conditions established by this IEE will be generally met.

In some cases, responsibility for appropriate environmental management of the activity may be appropriately assigned in the entirety to the governmental partner and/or host country environmental assessment and management authorities . Required considerations regarding degree of reliance on partner government entities for appropriate environmental management are ( 1) the environmental assessment and management capacity of these partners, and (2) the relative risk posed by the activities in question.

In each case, AEB will document in writing the proposed environmental compliance approach/arrangements for the activities in question and the justification for these arrangements, and obtain REO approval prior to implementation.

Attached to this Approval Document is the full IEE.

USAID Mozambique AEB IEE I Page 7167

APPROVAL OF ENVIRONMENT AL ACTION RECOMMENDED:

Activity Title: Mozambique Agriculture, Environment, and Business (AEB) IEE

CLEARANCE:

Mission Director:

CONCURRENCE:

AFR Bureau Environmental Officer:

Brian Hirsch

FILE No:

ADDITIONAL CLEARANCES:

Mission Environmental Officer: ~~ ;:;:?""" ~uar0canga

Approved: D Disapproved: D

AEB Office Director: ~nlrons Date~ Supervisory Program Officer: \ ~ "'f~Date• '1/~'f;:, /Sheila Y ng

Regional Environmental Officer: ___ _ ci~~~-~~ _____ Date: er jJ b l ;2.o J) Diana Shannon

Deputy Mission Director: -~~,__,,,_____.._.~------~ __ Date: 1LJ5fv1/5r ~Stumbras

Distribution List:

USAID/Mozambique AEB A/COR and Activity Managers USAID/Mozambique Office of Acquisitions and Assistance USAID/Mozambique Program Office

USAIO Mozambique AEB IEE I Page 8167