Attachment_J.8_Initial_Environmental_Examination.pdf

PROGRAM/ACTIVITY NAME CHANGE COVER SHEET for USAID ENVIRONMENTAL

DOCUMENTATION

This cover sheet is intended to capture changes in program/activity name(s) from those used in the subject environmental examination or request for categorical exclusion. Unless otherwise indicated below, the substantive aspects of the program/activity description and environmental analysis remain unchanged. This cover sheet is to be attached to the front of the subject environmental document.

PROGRAM/ACTIVITY DATA:

Program/Activity Number: ( 45869 )

Country/Region: SUDAN / EAST AFRICA_________________

Previous Program/Activity Title: Steps Towards Enduring Peace in Sudan (STEPS)

Current Program/Activity Title: __ Towards Enduring Peace in Sudan (TEPS)___________________

Date Title Changed: _________________

Funding Begin: FY 13 Funding End: FY 16 LOP Amount: $ $73,000,000 ____

Sub‐Activity Amount: N/A ______

IEE Prepared By: _Ken Spear ___ Date IEE Initially Prepared: _August 1, 2011____

IEE Expiration date: August 1, 2016 ___

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)

Categorical Exclusion: X Negative Determination: X

Positive Determination: Deferral:

Reason(s) for Title Change:

Mission Decision

INITIAL ENVIRONMENTAL EXAMINATION

AND/OR

CATEGORICAL EXCLUSION

PROGRAM/ACTIVITY DATA:

Program/Activity Number:

Project Award #: TBD Country/Region: Sudan/East Africa

USAID/Sudan Strategy: A transition country strategy: USAID/Sudan is mandated to enhance the viability and stability of Sudan in support of US Foreign Policy. As amended by the annual operational plan, there are two development objectives: Development Objective 1:

Sustainable Stability Enhanced in Priority Regions, and; Development Objective 2:

Good Governance Promoted through Decentralization and Citizen Participation.

Framework: Functional Objective: 1.6 Conflict Mitigation and Reconciliation Program Element: 1.6.1 Conflict Mitigation Program Element: 1.6.2 Peace and Reconciliation Processes

Program/Activity Title: USAID/Sudan Office of Transition and Conflict Mitigation’s Transition Initiative

Sudan (TIS) Program and Unsolicited Application from ACTED for Darfur Water Project (ACTED)

Funding Begin: FY 2011 funds Funding End: FY 2013funds (implementation period planned from FY 2011 through FY 2014) LOP Amount: $23 million USAID funds over two years (est.) for TIS and $500,000 for ACTED over one year (est.)

IEE Prepared By: Ken Spear, USAID Sudan OTCM Chief of Office, Khartoum Current Date: August 1, 2011 IEE Amendment (Y/N): N If "yes", Filename & date of original IEE: -------------------- IEE Expiration Date: August 1, 2016

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable) Categorical Exclusion: x Negative Determination: x .

Positive Determination: Deferral:

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

SUMMARY OF FINDINGS:

The Transition Initiative Sudan (TIS) Program and unsolicited application from ACTED for a water project in Darfur (ACTED) are mechanisms included in the USAID/Sudan Development Objective 1 Activity Approval Document. These activities support the draft USAID/Sudan transition strategy, as amended by the annual operational plan, by enhancing sustainable stability in priority regions. Importantly, the project endeavors to build the capacity of the Sudanese government and civil society to peacefully manage and mitigate conflict and to implement and participate in important political processes. This Initial Environmental Examination (IEE) provides Regulation 22 CFR 216 Threshold Determinations to ensure that all activities of the TIS and ACTED programs are environmentally sound.

Environmental Determinations Based on the use of a pro-active approach to integration of environmental management considerations into USAID programs – including incorporation of environmental quality considerations into procurement as appropriate, review procedures, promotion of environmental review, capacity building, and monitoring, evaluation and mitigation procedures specified in this IEE, to which the Mission commits itself, the following environmental determinations are recommended:

1 This planned award is one of two instruments being considered for the ‘Promoting stability through early recovery water supply’ mechanism covered in the USAID/Sudan DO1 AAD. The other instrument being considered is a public international organization grant to UNOPS, which will be covered under a separate IEE.

Categorical Exclusions are recommended for the following activities per 22 CFR 216.2 (c)(2)(i), education, technical assistance, or training; 216.2 (c)(2)(iii), analyses, studies, academic or research workshops and meetings; and 216.2 (c)(2)(v), document and information transfers:

Improved policy frameworks, case studies and support to implementation of political processes Improved Governance Capacity Workshops, Conferences and peace dialogues.

Provision of office equipment and supplies, and logistics Trainings for operations and maintenance of water points

Negative Determinations with Conditions per 22 CFR 216.3 (a)(2)(iii) are recommended for the activities aimed at supporting the outcomes of peace discussions such as renovation and rehabilitation of community training institutes and county government offices, youth centers , hand dug wells, rehabilitation of boreholes and wells and water yards.

Conditions are that all TIS and ACTED activities not qualifying for categorical exclusion shall be subjected to an environmental screening process to ensure appropriate environmental review is conducted as necessary and that such or future project activities are designed in an environmentally sound manner. This screening process is detailed in Section 3 and 4 of this document.

Monitoring and Evaluation As required by ADS 204.3.4, the USAID/Sudan Office of Transition Mitigation (with respect to the TIS Program) and the Program Office (with respect to the ACTED Program) will “actively monitor ongoing activities for compliance with approved IEE recommendations, and modify or end activities that are not in compliance" and ensure that adequate time and resources are available to bring all activities into compliance with the requirements of this IEE. If additional activities are added to this program and are not described in this document, an amended environmental examination must be prepared. These responsibilities may be shifted if AOTR responsibilities are transferred to other offices.

APPROVAL OF THE RECOMMENDED ENVIRONMENTAL ACTION:

CLEARANCE:

Mission Director: __cleared by Barbara Reed (Acting) _ Date: ___9/2/2011_________ David Young (Acting)

CONCURRENCE:

Africa Bureau Environmental Officer __concurrence_by Acting BEO WKnausenberger Date: 3/25/2013_ (for) Brian Hirsch File No: __________________

ADDITIONAL CLEARANCES:

COTR/AOTR or Team leader: ________/signed/_____________________ Date: _____8/21/2011___ Ken Spear

Mission Environmental Officer: ______________/cleared/__________ Date: ______________ Harry Bottenberg

Regional Environmental Officer: __cleared by email______________________Date: _9/6/2011________________ USAID/East Africa (Acting, AFR/SD) Walter Knausenberger

Program Officer ________/cleared___________ Date: _8/21/2011_____________ Ashley Marcus

Regional Legal Advisor: ____/cleared/_________________________ Date: ___8/25/2011__

David Young

USAID/Sudan Office of Transition and Conflict Mitigation’s Transition Initiative Sudan (TIS) Program and Unsolicited Application from ACTED for Darfur Water Project (ACTED)

INITIAL ENVIRONMENTAL EXAMINATION

Program/Activity: USAID/Sudan Office of Transition and Conflict Mitigation’s Transition Initiative Sudan (TIS)

Program and Unsolicited Application from ACTED for Darfur Water Project (ACTED) Country/Region: Sudan/Eastern Africa

1.0 BACKGROUND AND DESCRIPTION OF PROGRAM ACTIVITIES

In order to promote sustainable stability and enhance state viability in Sudan, the U.S. Government is assisting the Government of Sudan and its people in the area of political transition and conflict mitigation. It is expected that the USG through USAID will provide funding over the course of three years to support this program, which may be extended subject to an amendment to the activity approval document and this IEE. The TIS program will help the Sudanese in setting up conflict management systems, implementing recommendations from peace-building conferences, and implementing processes important for peaceful political transition among other activities. The ACTED program is expected to construct 30 hand dug wells and rehabilitate 10 existing water points (boreholes or wells) in 14 rural communities in West Darfur in addition to providing trainings for operations and maintenance of water points. The program is planned to be implemented over one year and a cost up to $500,000.

1.1 Purpose and Scope of this Initial Environmental Examination (IEE)

The purpose of this IEE is to provide the first review of the threshold determinations for the TIS/ACTED activities that will help promote peace and stability in Sudan. The IEE ensures that all activities of the program meet environmental compliance requirements in accordance with Regulation 22 CFR 216 and ADS 204, and provides for an environmental screening and review process to be integrated into program implementation. This IEE does not cover any procurement, handling and/or use of pesticides.

The IEE contains two types of findings. For most activities, the finding of Categorical Exclusion means that the activity is within a category that has been pre-determined to not have an impact on the environment. The finding of Negative Determination with Conditions means that the activity will not have an impact on the environment if the specified mitigation actions are taken and actively monitored.

2.0 COUNTRY AND ENVIRONMENTAL INFORMATION

2.1 Physical Environment

The topography of Sudan is comprised primarily of plains and hills forming a slope toward the Nile basin. An upland mountainous plateau, the Mara Mountains (3,088 meters) rises near the border with Chad in the west, and the Red Sea Hills lie behind the coast in the northeast. Blue Nile and South Kordofan states and Abyei area and the Darfur region are situated in the Sahel.

Temperatures in Sudan are typically above 25°C and can rise above 35°C, particularly during the dry season, which lasts from January to April. The hot, dry conditions trigger seasonal human and livestock migration to more permanent water sources (the toic), which serve as dry season grazing pasture, and for some ethnic groups they also serve as fishing grounds.

Northern areas of Darfur, Blue Nile and South Kordofan states, as well as Abyei Area, are dry with limited seasonal rainfall.

Sources:

Catterson et al, Sudan Environmental Threats and Opportunities Assessment, USAID, 2003.

2.2. Population

Sudan is located in the Greater Horn of Africa, which makes it particularly vulnerable to environmental and natural resource management issues that affect its development and prospects for delivery of educational services, good governance and political stability. According to the disputed 2008 census figures, the population of the Sudan is an estimated 31 million people and is largely rural in nature. Recently, there has been a marked increase in urban population due to rural-urban migration and an influx of refugees/returnees who have chosen not to return to the rural areas.

2.3 Locations Affected by the TIS/ACTED Programs

TIS Program activities are concentrated in the Three Areas (South Kordofan, Blue Nile and Abyei), Darfur, Eastern Sudan, and Khartoum and are focused on technical training, advising, workshops, conferences, equipment, supplies and logistical support for the implementation of political processes. These activities also contribute towards the rehabilitation of infrastructure in support of conflict mitigation and peace processes.

Africa Bureau Environmental Review Form 20 Dec 2010 2/25

ACTED program activities will be implemented in West Darfur. These activities will construct 30 hand dug wells and rehabilitate 10 existing water points (boreholes or wells) in 14 rural communities in West Darfur and providing the trainings for operations and maintenance of water points.

3.0 EVALUATION OF PROJECT/PROGRAM ISSUES WITH RESPECT TO ENVIRONMENTAL IMPACT

POTENTIAL

3.1 A number of activities are proposed under the TIS Program, including technical assistance to implementing popular consultations and other political processes, peace conferences, local governance and youth livelihoods. Most of the proposed activities are not anticipated to have any direct impacts on the environment and are thus recommended for categorical exclusions as per 22 CFR 216.2.

The following environmental determinations are recommended for activities proposed under the TIS Program:

Objective 1: Facilitate peace and reconciliation mechanisms between communities and local government to support stability and political transition with central government

Support will be initially through state and local government, traditional leaders and civil society in the Three Areas (South Kordofan, Blue Nile and Abyei) and Khartoum. Activities will support emerging political processes and will advance conditions for long-term stability through capacity building of local government and civil society to peacefully manage conflict and advocate for issues and constituencies. In Blue Nile and Southern Kordofan, activities will include but not be limited: to support to popular consultations and any follow-on mechanism that facilitates meaningful dialogue between the people and governments in these two states; technical assistance to government-led conflict management mechanisms;

technical and material support to civil society groups. In Abyei, activities may include capacity building and technical assistance support to the Abyei Area Administration and other bodies set up to manage the complicated transition of the Abyei Area. Finally, in Khartoum, activities will aim to build the capacity of civil society and to enhance and strengthen linkages between the government and civil society through provision of technical assistance, material and logistics support to dialogues, workshops, etc. Intended results include: improved capacity of state and local governance institutions and other entities supporting peaceful political processes and increased development through technical and material assistance.

No direct environmental impacts are anticipated to result from activities under this objective and therefore Categorical exclusions are recommended per 22 CFR 216.2 (c)(2)(i),education, technical assistance, or training, except to the extent that the activities directly affect the environment (such as construction of facilities); 216.2 (c)(2)(iii),analysis, studies, workshops and meetings; and 216.2 (c)(2)(v), document and information transfers.

Objective 2: Light infrastructure development

Positive interaction with communities is a critical element to promoting stability in war-affected societies. These interactions are generated in the form of quick-impact projects that are driven by the communities, primarily with the aim of demonstrating government response to community needs and demands. Projects concentrated in the Three Areas, Darfur and Eastern Sudan will include the repair/rehabilitation of existing infrastructure, and the provision of necessary materials and equipment to achieve this. TIS will facilitate a consultative process with the communities in order to identify and prioritize rehabilitation projects with the communities. This process will seek to build confidence and trust between state government and community in order to validate peace dividends and efforts. At a minimum, the following activities will be undertaken in these areas under this objective: community meetings and dialogue to determine projects; rehabilitation of schools, local markets, and government and public buildings, and; water repairs, supply and sanitation, community organizing for youth activities and/or rehabilitation of facilities.

Some modest environmental impacts are anticipated to result from some of the anticipated rehabilitation and repair activities under this objective, such as pollution related to disposal of debris from the old roofing material which may contain asbestos and impact on drainage caused by rehabilitation of pit latrines. Since many of the activities are not fully identified, the extent and nature of potential impacts are not fully known. A Negative Determination with Conditions per 22 CFR 216.3 (a)(2)(iii) is therefore recommended.

Objective 3: Livelihoods, income generation and job creation

Job creation and employment opportunities are critical to stability in Sudan. In addition to the light infrastructure development projects that act to provide immediate employment, small-scale activities will be supported in conjunction with local and international non-governmental organizations (NGOs), other USG implementers, and in conjunction with appropriate local authorities, to increase and strengthen livelihood opportunities. The identification and selection process will

Africa Bureau Environmental Review Form 20 Dec 2010 3/25 be the same flexible mechanism described earlier through consultative and technical assessment with the project stakeholders, including local government. These projects will be identified and implemented in partnership with local NGOs with experience in livelihood and/or vocational training project provision as well as through local government initiatives.

Productive employment and income generation projects provide citizens with meaningful opportunities to work towards community development, thereby reducing frustration and possible spoiler factors. USAID will continue programs to productively engage youth, women and other at-risk populations to provide constructive alternatives to participating in conflict activities and to spur economic growth at the grassroots level. Activities programmed through this intermediate result may also directly support outcomes of political and/or reconciliation processes should those outcomes call for livelihood improvements. At a minimum, the following activities will be undertaken: providing skills training, employment and entrepreneurial opportunities for targeted communities; quick employment through rehabilitation of community centers, clinics, etc,, and; increasing access to water and water management training to local community groups.

Since many of the activities are not fully identified, the extent and nature of potential impacts are not fully known. A Negative Determination with Conditions per 22 CFR 216.3 (a)(2)(iii) is therefore recommended.

Some modest environmental impacts are anticipated to result from some of the anticipated rehabilitation activities under this grant program, such as pollution related to disposal of debris from the old roofing material which may contain asbestos and impact on drainage caused by rehabilitation of pit latrines. Since many of the activities are not fully identified, the extent and nature of potential impacts are not fully known.

Negative Determination with Conditions per 22 CFR 216.3 (a)(2)(iii) is therefore recommended for activities falling under objectives 2 and 3 of the TIS, while a Categorical Exclusion per 22 CFR 216.2 (c)(2)(i); 216.2 (c)(2)(iii), and; 216.2 (c)(2)(v) is recommended for activities falling under objective 1. Conditions involve the use of appropriate environmental screening and review for all activities but those qualifying for categorical exclusion, per the above. This includes but is not limited to major renovations and construction, as well as livestock activities. The Environmental Review Form and Environmental Review Report (ERF/ERR) provided on the ENCAP website (see http://www.encapafrica.org/documents/AFR- EnvReviewForm-20Dec2010.doc) and attached to the end of this document as Annex A shall be tailored as needed to assist in identifying potential environmental impacts that may occur as a result of STCM activities. These ERF/ERRs will be reviewed and approved by the Sudan MEO and the Regional Environmental Officer. Mitigation measures identified in these ERF/ERRs shall be addressed in an Environmental Mitigation and Monitoring Plan (EMMP) approved by USAID for all activities classified as medium or high risk. See Annexes B and C, AND http://www.encapafrica.org/meo_resources/EMMP%20Templat%209May08.doc . The implementing partner must also ensure that all proposed activities are consistent with the Environmental Guidelines for Small-Scale Activities in Africa (EGSSA), available at http://www.encapafrica.org/egssaa.htm.

3.2 A number of activities are proposed under the ACTED Program include providing trainings in operations and maintenance of water points. Some of the proposed activities, particularly the trainings, are not anticipated to have any direct impacts on the environment and are thus recommended for categorical exclusions as per 22 CFR 216.2.

The following environmental determinations are recommended for activities proposed under the ACTED Program:

Positive interaction with communities is a critical element to promoting stability in war-affected societies. These interactions are generated in the form of quick-impact projects that are driven by the communities, primarily with the aim of demonstrating government response to community needs and demands. Projects will include the repair/rehabilitation of existing water and sanitation infrastructure in fourteen communities in Darfur, and the provision of necessary materials and equipment to achieve this. ACTED will facilitate a consultative process with the communities in order to identify and prioritize rehabilitation projects with the communities. This process will seek to build confidence and trust between state government and community in order to validate peace dividends and efforts.

Some modest environmental impacts are anticipated to result from some of the anticipated rehabilitation and repair activities under this objective, such as pollution related to construct 30 hand dug wells and rehabilitate 10 existing water points (boreholes or wells) in 14 rural communities in West Darfur.

Negative Determination with Conditions per 22 CFR 216.3 (a)(2)(iii) is therefore recommended for this activity.

Conditions involve the use of appropriate environmental screening and review for all activities but those qualifying for categorical exclusion, per the above. This includes but is not limited to major renovations and construction, as well as livestock activities. The Environmental Review Form and Environmental Review Report (ERF/ERR) provided on the ENCAP website (see http://www.encapafrica.org/documents/AFR-EnvReviewForm-20Dec2010.doc) and attached to the end of this document as Annex A shall be tailored as needed to assist in identifying potential environmental impacts that may

Africa Bureau Environmental Review Form 20 Dec 2010 4/25 occur as a result of STCM activities. These ERF/ERRs will be reviewed and approved by the Sudan MEO and the Regional Environmental Officer. Mitigation measures identified in these ERF/ERRs shall be addressed in an Environmental Mitigation and Monitoring Plan (EMMP) approved by USAID for all activities classified as medium or high risk. See Annexes B and C, AND http://www.encapafrica.org/meo_resources/EMMP%20Templat%209May08.doc. The implementing partner must also ensure that all proposed activities are consistent with the Environmental Guidelines for Small-Scale Activities in Africa (EGSSA), available at http://www.encapafrica.org/egssaa.htm.

4.0 RECOMMENDED THRESHOLD DETERMINATIONS & MITIGATION ACTIONS (INCLUDING

MONITORING AND EVALUATION)

4.1 Activities Recommended for Categorical Exclusion from Further Environmental Review

Categorical exclusions are recommended for all activities associated with Objective 1 most of Objective 3 activities under the TIS Program and the training aspects of the ACTED program. Specifically, this includes all activities that fall under the following subsections of 22 CFR 216.2(c):

(i) Education, technical assistance, or training: For activities involving technical assistance and professional staff training to support the local government and communities in the target populations.

(ii) Analyses, studies, academic or research workshops and meetings: For activities involving assessments, workshops, and reports and sharing of best practices in for conflict mitigation and political processes.

(v) Document and information transfers: For activities involving the development of guides, supply of learning material, development of policy recommendations, and installation of management information systems at existing local government institutions for ease of management.

Negative Determinations with Conditions are recommended for some activities in Objective 2 and some activities in Objective 3 under the TIS Program as well as the activities under the ACTED Program, such as the rehabilitation of community infrastructure and increasing water access. Per 22 CFR 216.3 (a)(2)(iii). Conditions involve the use of appropriate environmental screening and review for all activities but those qualifying for categorical exclusion, per the above. This includes but is not limited to major renovations and construction, as well as livestock activities. The Environmental Review Form and Environmental Review Report provided on the ENCAP website (see http://www.encapafrica.org/documents/compliance_forms/AFR-EnvReviewForm-17Jan05.doc) and attached to the end of this document as Annex A and Annex B shall be tailored as needed to assist in identifying potential environmental impacts that may occur as a result of STCM activities. These ERF/ERRs will be reviewed and approved by the Sudan MEO and the Regional Environmental Officer. Mitigation measures identified in these ERF/ERRs shall be addressed in an Environmental Mitigation and Monitoring Plan (EMMP) approved by USAID for all activities classified as medium or high risk. The implementing partner must also ensure that all proposed activities are consistent with the Environmental Guidelines for Small-Scale Activities in Africa (EGSSA), available at http://www.encapafrica.org/egssaa.htm. Additionally, a Recommended Environmental Mitigation and Monitoring Plan (EMMP) Template is attached to this document as Annex C.

4.2 Mitigation, Monitoring and Evaluation Measures

Mitigation and monitoring measures for categorical exclusions and negative determinations with conditions are necessary to ensure that no adverse impacts occur once the proposed program activities are implemented. The implementing partner will be required to maintain a continuous monitoring and evaluation process for ensuring compliance with environmental guidelines for all ongoing and proposed program activities to ensure they remain as categorical exclusions or within the bounds of the negative determination with conditions.

To ensure that environmental screening and review processes are applied in conformity with the recommended environmental procedures, they are summarized below:

Implementing partners will take into consideration potential environmental impacts and their mitigation, including avoidance, and will design, implement and monitor their activities to achieve environmental sustainability.

Implementing partners responsible for awarding grants will screen activities according to the Africa Bureau Screening and Environmental Review Process.

Implementing partners will take into account the Environmental Guidelines for Small-Scale Activities in Africa and other appropriate Bureau and generic environmental assessment sources to assist in determining what potential impacts should be of concern for different types of development activities in various settings and which impacts to mitigate and monitor for a particular development activity.

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Implementing partners must identify in the Environmental Review reports all proposed environmental mitigation and monitoring requirements. Once the Environmental Review reports are approved, the mitigation measures and monitoring procedures stated in the Environmental Review report shall be considered a requirement and an Environmental Mitigation and Monitoring Plan should be developed addressing these measures. A Recommended Environmental Mitigation and Monitoring Plan (EMMP) Template is attached to this document as Annex C. Also, refer to http://www.encapafrica.org/meo_resources/EMMP%20Templat%209May08.doc

Implementers will ensure the implementation of agreed-upon mitigation measures and environmental impact monitoring.

Implementing partners' annual reports and, as appropriate, progress reports shall contain a brief update on mitigation measures being implemented, results of environmental monitoring, and any major modifications/revisions to the activities, mitigation measures or monitoring procedures.

USAID/Sudan must report on an annual basis (and in more detail as the BEO may require) on the status of environmental screening and review and the implementation of mitigation and monitoring requirements. This will include review of implementing partners' progress and annual reports and EMMP to help determine if environmental mitigation and monitoring procedures are in place and are successful.

USAID/Sudan will incorporate into Mission field visits and consultations with implementing partners periodic examination of the environmental impacts of activities and associated mitigation and monitoring (assistance of the BEO or REO/REA in preparing guidelines or assisting with the monitoring and evaluation can be solicited).

USAID/Sudan is responsible for monitoring and evaluation of activities after implementation with respect to environmental effects, a process which should be integrated into the Mission's pertinent Performance Monitoring and Evaluation Plan, and through periodic field visits.

Africa Bureau Environmental Review Form 20 Dec 2010 6/25

Annexes

Annex A:

Note to USAID Staff, Consultants & Partners Regarding the:

Africa Bureau ENVIRONMENTAL REVIEW FORM & INSTRUCTIONS

Appropriate use

1. The Environmental Review Form (ERF) can only be used when and as specifically authorized by the IEE or EA governing the project or program in question. For IEEs, this authorization is made in the form of a negative determination with conditions.

Authorized use of the ERF is limited to the specific class of activities enumerated in the determination.

2. The BEO will not clear an IEE or EA that authorizes use of the ERF unless ALL of the following are true:

a. the general nature or potential scope of the activities for which the ERF will be used are known at the time the IEE is written (e.g. small infrastructure rehabilitation, training and outreach for a specified purpose, etc.).

b. these activities will be executed under a grant or subproject component of a parent project/program. The ERF cannot be used in lieu of a request for categorical exclusion, IEE or IEE amendment when new activities/components are to be added to existing projects, programs or sector portfolios.

c. of their general nature, foreseeable adverse environmental impacts are small or easily controllable with BASIC MITIGATION TECHNIQUES that can BE SUCCESSFULLY IMPLEMEMENTED BY FIELD STAFF.

d. of their general nature, the activities are NOT large‐scale.

There is no formal AFR standard for “small‐scale activities.” Over time, AFR has developed some “rules of thumb” for activities that are BOTH small‐scale AND pose very low risks of significant adverse impacts. These are used in the ERF itself:

e.g. construction involving less than 10,000 sq ft total disturbed area and less than $200,000 total cost; road rehabilitation of less than 10km total length without change to alignment or right‐of‐way. Activities moderately larger than these “rules of thumb” are also small‐scale, but are treated by the ERF as being of moderate/unknown risk, thus requiring an environmental review report.

What does “moderately larger” mean? What about activities for which there is no “rule of thumb” built into the ERF?

Absolute physical scale and funding level, physical scale relative to the surrounding built environment, population affected, and number of locations affected are among the factors relevant to determining whether a class of activities is “small scale.”

The IEE must provide enough information for the BEO to assess whether the activities proposed for subproject review will be indeed be small scale within their implementation context.

Adaptation of the form

1. Text in UNDERLINE & BLUE HIGHLIGHT MUST be customized to the particular project/mission.

2. Yellow highlighted text must be reviewed and then modified, deleted or retained, as appropriate.

3. Both the form AND instructions should be generally reviewed and modified to reflect the specific project/program and implementation context.

4. The adapted form and instructions must be appended to the Initial Environmental Examination for the overall project.

5. For NRM‐oriented programs (especially those involving CBNRM, ecotourism, enterprises exploiting non‐timber forest products, etc.) consider adaptation and use of the Supplemental Environmental Review Form for NRM sector activities.

Questions and Guidance General guidance on subproject review is available on the MEO Resource Center at www.encapafrica.org/meoEntry.htm. For specific questions, contact the Mission Environmental Officer or Regional Environmental Advisor. Good‐practice examples of completed forms, environmental review reports and environmental management plans are available from USAID/AFR’s ENCAP project:

Download at http://www.encapafrica.org/documents/AFR-EnvReviewForm-20Dec2010.doc version 20 Dec 2010

Africa Bureau Environmental Review Form 20 Dec 2010 7/25 encapinfo@cadmusgroup.com; www.encapafrica.org.

Revision history:

Major update on 24 June 2010 to clarify appropriate use, revise Env Review Report structure, and update clearance requirements.

Formatting and presentation revised 17 Jan 2005. Revised April 13, 2004, to include biosafety considerations and better reflect the Supplemental Environmental Review Form for NRM sector activities.

DELETE THIS PAGE BEFORE DISTRIBUTING THIS FORM

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Instructions for environmental review of XXX Program Subprojects/Sub-grants

Note: These instructions accompany the attached “Environmental Review Form for USAID/XXX Program/Project Activities” (ERF). Follow, but DO NOT SUBMIT, these instructions.

Who must submit the Environmental Review Form (ERF)?

ALL Implementing Partners seeking to implement [describe qualifying activities] under the XXX Program/Project must complete, sign and submit the ERF to [insert name & email of C/AOTR].

Authority: Use of the ERF for these activities is mandated by the governing Initial Environmental Examination (IEE) for the XXX Project/Program. The IEE can be downloaded at: [insert URL].

No implementation without an approved ERF The proposed activities cannot be implemented and no “irreversible commitment of resources” for these activities can be made until the ERF (including Environmental Review Report, if required, see Step 4, below) is cleared by the C/AOTR, the Mission Environmental Officer (MEO) and the Regional Environmental Advisor (REA).

NOTE: USAID may deny clearance to the ERF, or may require modification and re-submission for clearance.

Environmental management requirements resulting from the ERF If the ERF requires preparation of an Environmental Review Report (see Step 4, below), any environmental management measures specified in the approved Environmental Review Report MUST be implemented.

Situations in which additional environmental review is required.

If the ERF finds that one of more of the proposed activities has the potential to cause significant adverse environmental impacts, the activities must be redesigned or an IEE or full Environmental Assessment must be conducted and approved prior to implementation.

If USAID determines that the proposed activities are outside the scope of activities for which use of this form is authorized, the activities must be redesigned or an IEE or IEE Amendment will be required.

In either situation, USAID will confer with the partner to determine next steps. Note: If an IEE or EA is required, all environmental management measures specified in the IEE or EA must then be implemented.

Step 1. Provide requested “Applicant information” (Section A of the ERF) Step 2. List all proposed activities In Section B of the form, list all proposed activities.

Activities are a desired accomplishment or output: e.g. seedling production, road rehabilitation, school construction. Each activities has entailed actions—for example, road rehabilitation includes survey, grading, culvert construction, compaction, etc. Be aware of these entailed actions, but do NOT list them.

List activities DESCRIPTIVELY. For example, “training” is not a sufficient activity listing. The listing must specify WHO is being trained, and in WHAT.

Step 3a. Screening: Identify low-risk and high-risk activities For each activity you have listed in Section B of the form, refer to the list below to determine whether it is a listed low-risk or high-risk activity.

If an activity is specifically identified as “very low risk” or “high risk” in the list below, indicate this in the “screening result” column in Section B of the form.

Very low-risk activities (Activities with low potential for adverse biophysical or health impacts; including §216.2(c)(2))

High-risk activities (Activities with high potential for adverse biophysical or health impacts; including §216.2(d)(1))

AFR Environmental Review Form Instructions 20 Dec 2010

Very low-risk activities (Activities with low potential for adverse biophysical or health impacts; including §216.2(c)(2))

High-risk activities (Activities with high potential for adverse biophysical or health impacts; including §216.2(d)(1))

Provision of education, technical assistance, or training. (Note that activities directly affecting the environment. do not qualify.)

Community awareness initiatives.

Controlled agricultural experimentation exclusively for the purpose of research and field evaluation confined to small areas (normally under 4 ha./10 acres). This must be carefully monitored and no protected or other sensitive environmental areas may be affected).

Technical studies and analyses and other information generation activities not involving intrusive sampling of endangered species or critical habitats.

Document or information transfers.

Nutrition, health care or family planning, EXCEPT when (a) some included activities could directly affect the environment (construction, water supply systems, etc.) or

(b) biohazardous (esp. HIV/AIDS) waste is handled or blood is tested.

Small-scale construction. Construction or repair of facilities if total surface area to be disturbed is under 10,000 sq. ft. (approx. 1,000 sq. m.) (and when no protected or other sensitive environmental areas could be affected).

Intermediate credit. Support for intermediate credit arrangements (when no significant biophysical environmental impact can reasonably be expected).

Maternal and child feeding conducted under Title II of Public Law 480.

Title II Activities. Food for development programs under Title III of P.L. 480, when no on-the-ground biophysical interventions are likely.

Capacity for development. Studies or programs intended to develop the capability of recipients to engage in development planning. (Does NOT include activities directly affecting the environment)

Small-scale Natural Resource Management activities for which the answer to ALL SUPPLEMENTAL SCREENING QUESTIONS (see Natural Resources supplement) is “NO.”

River basin development

New lands development

Planned resettlement of human populations.

Penetration road building, or rehabilitation of roads (primary, secondary, some tertiary) over 10 km length, and any roads which may pass through or near relatively undegraded forest lands or other sensitive ecological areas

Substantial piped water supply and sewerage construction.

Major bore hole or water point construction.

Large-scale irrigation; Water management structures such as dams and impoundments

Drainage of wetlands or other permanently flooded areas.

Large-scale agricultural mechanization.

Agricultural land leveling.

Procurement or use of restricted use pesticides, or wide-area application in non-emergency conditions under non-supervised conditions. (Consult MEO.)

Light industrial plant production or processing (e.g., sawmill operation, agro-industrial processing of forestry products, tanneries, cloth-dying operations).

High-risk and typically not funded by USAID:

Actions affecting protected areas and species.

Actions determined likely to significantly degrade protected areas, such as introduction of exotic plants or animals.

Actions determined likely to jeopardize threatened & endangered species or adversely modify their habitat (esp. wetlands, tropical forests)

Activities in forests, including:

Conversion of forest lands to rearing of livestock

Planned colonization of forest lands

Procurement or use of timber harvesting equipment

Commercial extraction of timber

Construction of dams or other water control structures that flood relatively undegraded forest lands

Construction, upgrading or maintenance of roads that pass through relatively non-degraded forest lands. (Includes temporary haul roads for logging or other extractive industries)

(This list of activities is taken from the text of 22 CFR 216 and other applicable laws, regulations and directives)

Step 3b: Identifying activities of unknown or moderate risk.

All activities NOT identified as “very low risk” or “very high risk” are considered to be of “unknown or moderate risk.”

Common examples of moderate-risk activities are given in the table below.

Check “moderate or unknown risk” under screening results in Section B of the form for ALL such activities.

Common examples of moderate-risk activities

CAUTION:

If ANY of the activities listed in this table may adversely impact (1) protected areas, (2) other sensitive environmental areas, or (3) threatened and endangered species and their habitat, THEY ARE NOT MODERATE RISK. All such activities are HIGH RISK ACTIVITIES.

Small-scale agriculture, NRM, sanitation, etc. (You may wish to define what “small scale” means for each activity)

Agricultural experimentation. Controlled and carefully monitored agricultural experimentation exclusively for the purpose of research and field evaluation of MORE than 4 ha.

NOTE Biotechnology/GMOs: No biotechnology testing or release of any kind are to take place within an assisted country until the host countries involved have drafted and approved a regulatory framework governing biotechnology and biosafety.

All USAID-funded interventions which involve biotechnologies are to be informed by the ADS 211 series governing "Biosafety Procedures for Genetic Engineering Research". In particular this guidance details the required written approval procedures needed before transferring or releasing GE products to the field.

Medium-scale construction. Construction or rehabilitation of facilities or structures in which the surface area to be disturbed exceeds 10,000 sq. ft (1000 sq meters) but funding level is $200,000 or less. (E.g. small warehouses, farm packing sheds, agricultural trading posts, produce market centers, and community training centers.)

Rural roads. Construction or rehabilitation of rural roads meeting the following criteria:

Length of road work is less than ~10 km

No change in alignment or right of way

Ecologically sensitive areas are at least 100 m away fr om the road and not affected by construction or changes in drainage.

No protected areas or relatively undegraded forest are within 5 km of the road.

Title II & III Small-Scale Infrastructure. Food for Development programs under Title II or III, involving small-scale infrastructure with the known potential to cause environmental harm (e.g., roads, bore holes).

Quantity imports of commodities such as fertilizers

Sampling. Technical studies and analyses or similar activities that could involve intrusive sampling, of endangered species or critical habitats. (Includes aerial sampling.)

Water provision/storage. Construction or rehabilitation of small-scale water points or water storage devices for domestic or non-domestic use.

Water points must be located where no protected or other sensitive environmental areas could be affected.

NOTE: USAID guidance on water quality requires testing for arsenic, nitrates, nitrites and coliform bacteria.

Support for intermediate credit institutions when indirect environmental harm conceivably could result.

Institutional support grants to NGOs/PVOs when the activities of the organizations are known and may reasonably have adverse environmental impact.

Pesticides. .Small-scale use of USEPA-registered, least-toxic general-use pesticides. Use must be limited to NGO-supervised use by farmers, demonstration, training and education, or emergency assistance.

NOTE: Environmental review (see step 5) must be carried out consistent with USAID Pesticide Procedures as required in Reg. 16 [22 CFR 216.3(b)(1)].

Nutrition, health care or family planning, if (a) some included activities could directly affect the environment (e.g., construction, supply systems, etc.) or (b) biohazardous healthcare waste (esp.

HIV/AIDS) is produced, syringes are used, or blood is tested.

Step 4. Determine if you must write an Environmental Review Report Examine the “screening results” as you have entered them in Table 1 of the form.

If ALL the activities are “very low risk,” then no further review is necessary. In Section C of the form, check the box labeled “very low risk activities.” Skip to Step 8 of these instructions.

If ANY activities are “unknown or moderate risk,” you MUST complete an ENVIRONMENTAL REVIEW REPORT addressing these activities. Proceed to Step 5.

If ANY activities are “high risk,” note that USAID’s regulations usually require a full environmental assessment study (EA). Because these activities are assumed to have a high probability of causing significant, adverse environmental impacts, they are closely scrutinized. Any proposed high-risk activity should be discussed in advance with USAID. Activity re-design is often indicated.

Africa Bureau Environmental Review Form 20 Dec 2010 4/25

In some cases, it is possible that reasonable, achievable mitigation and monitoring can reduce or eliminate likely impacts so that a full EA will not be required. If the applicant believes this to be the case, the Environmental Review Report must argue this case clearly and thoroughly. Proceed to Step 5.

Step 5. Write the Environmental Review Report, if required The Environmental Review Report presents the environmental issues associated with the proposed activities. It also documents mitigation and monitoring commitments. Its purpose is to allow the applicant and USAID to evaluate the likely environmental impacts of the project.

For a single, moderate risk activity, the Environmental Review Report is typically a SHORT 4–5 page document. The Report will typically be longer for (1) multiple activities; (2) activities of high or unknown risk; and/or (3) when a number of impacts and mitigation measures are being identified and discussed.

The Environmental Review Report follows the outline below. Alternate outlines are acceptable, so long as all required information is covered.

A. Summary of Proposal. Very briefly summarize background, rationale and outputs/results expected. (Reference proposal, if appropriate).

B. Description of Activities. For all moderate and high-risk activities listed in Section B of the ERF, succinctly describe location, siting, surroundings (include a map, even a sketch map). Provide both quantitative and qualitative information about actions needed during all project phases and who will undertake them. (All of this information can be provided in a table). If various alternatives have been considered and rejected because the proposed activity is considered more environmentally sound, explain these.

C. Site-specific Environmental Situation & Host Country Requirements. Describe the environmental characteristics of the site(s) where the proposed activities will take place. Focus on site characteristics of concern— e.g., water supplies, animal habitat, steep slopes, etc. With regard to these critical characteristics, is the environmental situation at the site degrading, improving, or stable?

Also note applicable host country environmental regulations and/or policies. (For example, does the project require host country environmental review or permitting? Building approval? Etc.)

NOTE: provide site-specific information in this section, NOT country-level information. General information about country level conditions should already be contained in the IEE governing the XXX project/program.

D. Environmental Issues, Mitigation Actions, and Findings. For ALL proposed activities

i. Briefly note the potential environmental impacts or concerns presented by the proposed activities (if any). For guidance, refer to Africa Bureau’s Environmental Guidelines for Small-Scale Activities;

available at www.encapafrica.org/egssaa.htm.

As per the Small-Scale Guidelines, consider direct, indirect and cumulative impacts across the activity lifecycle (i.e. impacts of site selection, construction, and operation, as well as any problems that might arise with abandoning, restoring or reusing the site at the end of the anticipated life of the facility or activity). Note that “environment” includes air, water, geology, soils, vegetation, wildlife, aquatic resources, historic, archaeological or other cultural resources, people and their communities, land use, traffic, waste disposal, water supply, energy, etc.)

ii. Assess the extent to which these potential impacts and concerns are significant in the context of the specific activity design and site.

iii. Set out the…