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INITIAL ENVIRONMENTAL EXAMINATIONACTIVITY DATAActivity Name: USAID Food for Peace (FFP) FY18 Request for

Applications (RFA)Amendment (Y/N): NoGeographic Location(s) (Country/Region):

Burkina Faso-Central Northern Region; Niger-Zinder & Maradi

Implementation Start/End: Pre-Award, To be determined upon award(s)Solicitation/Contract/Award Number:

FY18 FFP RFA

Implementing Partner(s): To be determined upon award(s)Link to IEE: DCHA FFP FY18 RFA IEELink of Other, Related Analyses: RISE2 PAD-IEE, REGIS PERSUAP1

ORGANIZATIONAL/ADMINISTRATIVE DATA

Implementing Operating Unit(s): (e.g. Mission or Bureau or Office)

Office of Food for Peace (FFP), Bureau for Democracy, Conflict and Humanitarian Assistance (DCHA)

Funding Operating Unit(s): (e.g. Mission or Bureau or Office)

Same as above

Funding Account(s): Burkina FASO-FFP Title II resources; Niger-USAID Bureau for Food Security Community Development Funds (CDF) or FFP Title II resources

Funding Amount: Burkina Faso-$50 million over 5 years; Niger-$150 million over 5 years for up to 3 awards

Other Affected Unit(s): Africa Bureau, Regional Mission DakarLead BEO Bureau: Democracy, Conflict and Humanitarian

Assistance (DCHA) Prepared by: Global Environmental Management Support

(GEMS) IIDate Prepared: February 1, 2018

ENVIRONMENTAL COMPLIANCE REVIEW DATAAnalysis Type: Initial Environmental Examination Environmental Determination(s): Positive Determination, DeferralInitial Environmental Examination 2023, End of Awards1 Pending approval; links not yet available.

USAID/DCHA FFP FY18 RFA IEE 1

https://www.usaid.gov/food-assistance/what-we-do/development-activities

Expiration Date:Additional Analyses/Reporting Required:

Implementing partners to develop supplemental Activity-level IEEs

Climate Risk Rating for Risks Identified:

Low __X___ Moderate __X___ High __X___

THRESHOLD DECISION MEMO AND SUMMARY OF FINDINGSPURPOSE AND SCOPE OF THE INITIAL ENVIRONMENTAL EXAMINATIONThe purpose of this Initial Environmental Examination is to establish environmental compliance procedures and templates for future awarded activities under the Food for Peace (FFP) Fiscal Year 2018 Request for Application (RFA) for Burkina Faso and Niger Development Food Security Activities.

ACTIVITY SUMMARY As specified in the Country Specific Information (CSI) for Burkina Faso and Niger these activities will contribute to the achievement of country government resilience, economic and social development plans while serving as the foundation for USAID’s Resilience in the Sahel Enhanced II (RISE II) initiative, which aims to help “chronically vulnerable populations in Burkina Faso and Niger, supported by resilient systems, effectively manage shocks and stresses and pursue sustainable pathways out of poverty.”

ENVIRONMENTAL DETERMINATIONS A Positive Determination, is recommended for all commodity fumigation activities, pursuant to 22 CFR 216.3(b)(l)(iii). A Deferral is recommended for all other interventions, pursuant to 22 CFR 216.3(a)(7)(iv), that are not yet well defined in scope or technical approach.

CLIMATE RISK MANAGEMENT During Climate Risk Management Screening, both low, moderate, and high climate risks were identified for Commodity Fumigation.

Climate Risk Management Screening for Other FFP Program Areas and Elements will be conducted once activities are more well defined in scope, likely simultaneously with supplemental Activity-level IEEs. Many of the areas and elements will likely have some high climate risks.

BEO SPECIFIED CONDITIONS OF APPROVAL

AT THE PRE-AWARD STAGE, PROPOSAL STAGE: Condition 1: Develop Environmental Safeguards Plan. Developed by applicants to the RFA, the plan summarizes how the activity will reduce environmental impacts of and climate risks to interventions, including plans for institutional arrangements (i.e. budget, staffing) to implement such environmental risk reduction actions.



AT THE POST-AWARD, ACTIVITY-LEVEL IEE STAGE: Condition 2: Develop Activity-Level IEE, CRM screening and EMMP. Each awardee must develop an Activity-level IEE, CRM screening and EMMP in coordination with findings of the FFP M&E Workshop.

Condition 3: Develop an Environmental Assessment for action with significant effect, as determined by USAID. For activities with potential for significant environmental effect, USAID may require partners to complete a full environmental impact assessment process.

Condition 4: Integrate environmental considerations, including Climate Risks, into M&E Systems. This requirement is described within the Policy and Guidance for Monitoring, Evaluation, and Reporting of Development Food Security Activities.

Condition 5: Ensure a sufficient and transparent environmental compliance budget. This environmental compliance budget will ensure necessary funding is available for IEE and EMMP implementation over the course of the multi-year activity.

Condition 6: Plan for a Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP). Pursuant to 22 CFR 216.3(b), DCHA/BEO approval is required under the guidance of a PERSUAP prior to promotion, procurement, transport, storage or disposal of any pesticides.

Condition 7: Monitor and report on USAID environmental compliance. All activities are required to develop Environmental Status Reports (ESRs)* annually. Additional compliance and performance reporting is reflected in the Annual Results Report (ARR).

Condition 8: Ensure Compliance with partner country regulations. Implementation will adhere to applicable partner country environmental laws (see Section 2 for overview of laws).

IMPLEMENTATIONIn accordance with 22 CFR 216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Sections 3, 4, and 5 of the IEE, including any BEO Specified Conditions.

**The ESR is similar to the Environmental Mitigation and Monitoring Report (EMMR) used elsewhere in USAID. However, the ESR meets both purposes of reporting and budget planning for environmental compliance.


http://pdf.usaid.gov/pdf_docs/PBAAF103.pdf



USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

ACTIVITY NAME: USAID Food for Peace (FFP) FY18 Request for Applications Initial Environmental Examination (RFA IEE) for Development Food Security Activities in Burkina Faso and Niger

Bureau Tracking ID: DCHA FFP FY18 RFA IEE

Approval: ________________________________________________Matthew Nims: FFP Director

_____________Date

Clearance: ________________________________________________FFP Grants Manager

_____________Date

Clearance: ________________________________________________Kyle Rearick: DCHA Climate Integration Lead

_____________Date

Concurrence:________________________________________________Erika J. Clesceri: DCHA Bureau Environmental Officer

_____________Date

DISTRIBUTION: Brian Hirsch (Africa BEO), Walter Knausenberger (Africa Bureau), Roopa Karia (Africa Bureau), Samantha Wapnick (Sahel Regional Office REO), Abdourahmane N’diaye (Sahel Regional Office Deputy REO & MEO), Siaka Millogo (Burkina Faso FFP Team Leader), and Beth Ceryak (FFP Grants Management Specialist).


TABLE OF CONTENT

S

1.0 ACTIVITY DESCRIPTION__________________________________________________61.1 Purpose and Scope of IEE____________________________________________61.2 Activity Overview____________________________________________________61.3 Activity Description__________________________________________________7

2.0 BASELINE ENVIRONMENTAL INFORMATION_______________________________82.1 Locations Affected and Environmental Context_______________________82.2 Applicable and Appropriate Partner Country and Other International Standards (e.g. WHO), Environmental and Social Laws, Policies, and Regulations____________________________________________________________13

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK________________________15 Commodity Fumigation_________________________________________________15 Other FFP Program Areas and Elements________________________________16

4.0 ENVIRONMENTAL DETERMINATIONS____________________________________164.1 Recommended Environmental Determinations______________________164.2 Climate Risk Management__________________________________________17

5.0 CONDITIONS AND MITIGATION MEASURES______________________________205.1 Conditions__________________________________________________________205.1.1 During Pre-Award Stage__________________________________________205.1.2 During Post-Award Stage_________________________________________20

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION__________277.0 REVISIONS_____________________________________________________________27

Attachments:______________________________________________________________28 ANNEX 1: Template for Activity-llevel Initial Environmental Examinations_29 ANNEX 2: Template for Environmental Mitigation and Monitoring Plans__39 ANNEX 3: Template for Environmental Status Reports___________________40 ANNEX 4: Guidance for Climate Risk Management Screening____________46


1.0 ACTIVITY DESCRIPTION1.1 PURPOSE AND SCOPE OF IEE The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID interventions described herein and recommend determinations and, as appropriate, conditions, for these activities. Upon approval, these determinations become affirmed, per 22 CFR 216 and BEO Specified Conditions become mandatory obligations of implementation. This RFA-level IEE (herein, “RFA IEE”) also includes the RFA-level Climate Risk Management screening results in accordance with USAID policy (specifically, ADS 201mal).

This RFA IEE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation. This RFA IEE also establishes the requirements for post-award implementing partners (IPs) to develop their own supplemental Activity-level IEEs and outlines other BEO Specified Conditions for implementation and reporting throughout the life of the awards.

1.2 ACTIVITY OVERVIEW The Office of Food for Peace (FFP), in the U.S. Agency for International Development’s (USAID) Bureau for Democracy, Conflict, and Humanitarian Assistance (DCHA), is the U.S. Government leader in international food assistance. Through FFP, USAID supports multi-year development (i.e., non-emergency) food security activities to improve and sustain the food and nutrition security of vulnerable populations. Development activities are mandated in the Food for Peace Act and are aligned with the FFP 2016-2025 Food Assistance and Food Security Strategy. These activities work at the individual, household, and systems level to address the underlying causes of chronic food insecurity and strengthen transformative opportunities. USAID also provides emergency food assistance to address needs arising from natural disasters and complex emergencies, which are often characterized by insecurity and population displacement.

Overall, the FFP Strategic Results Framework Strategic Objectives (SOs) and accompanying Intermediate Results (IRs) address key drivers of food insecurity, creating a map of the broad platform of capabilities that FFP and its partners bring to bear in supporting improved food security for vulnerable populations. Implementing partners are expected to use innovative approaches to promote environmental risk management to improve and sustain food and nutrition security of vulnerable populations, as articulated in both SO1 and SO2 of the FFP 2016-2025 Food Assistance and Food Security Strategy.

As specified in the Country Specific Information (CSI) for Burkina Faso and Niger Development Food Security Activities, FFP investments will contribute to the


achievement of the Government of Burkina Faso’s (GoBF) National Plan for Economic and Social Development (PNDES) or the Government of Niger’s (GoN’s) Resilience Strategy, as well as USAID’s FFP Strategy. They will also serve as the foundation for USAID’s Resilience in the Sahel Enhanced II (RISE II) initiative, which aims to help “chronically vulnerable populations in Burkina Faso and Niger, supported by resilient systems, effectively manage shocks and stresses and pursue sustainable pathways out of poverty.” FFP investments will work in coordination with other investments by the U.S. Government (USG), the World Food Program (WFP), the host country governments, and other donors to collectively benefit chronically vulnerable populations in the RISE II zone. While the FFP activity(ies) may support many of the Intermediate Results (IRs) and sub-IRs under this results framework, it is expected that the FFP activity(ies) will focus primarily on the household, community, and commune level interventions. Other RISE II investments will focus on complementary activities at the community, commune, regional and national levels.

1.3 ACTIVITY DESCRIPTIONFFP development food security activities in Burkina Faso and Niger are intended to build resilience in populations vulnerable to chronic hunger and repeated hunger crises, and to reduce their future need for ongoing or emergency food assistance. To these ends, the FFP office supports the procurement, protection, and distribution of food commodity, including fumigation, as well as a range of program areas and elements.

COMMODITY FUMIGATIONFFP makes commodity donations to private voluntary organizations (PVOs) and international organizations (IOs), such as the UN’s World Food Program (WFP). The large majority of FFP commodities are purchased from US farmers and shipped abroad from US ports; however, activities can also distribute locally/regionally procured (LRP) food commodity as long as the use of LRP clearly supports interventions that sustainably reduce vulnerability to food insecurity.

In order to prevent the spoilage and wasting of food commodity procured by development food security activities, a range of protective measures are implemented in commodity storage warehouses. One common protective measure to prevent loss of commodity from insect, fungal or mammal infestations is fumigation utilizing phosphine gas and/or the application of contact pesticides to warehouse surfaces.

OTHER FFP PROGRAM AREAS AND ELEMENTS2

The range of program areas and elements which may be supported within these development food security activities are listed below and further described in the FY18 FFP RFA.

TABLE 1: DEFINED INTERVENTIONS

2 As Defined in the FY18 FFP RFA.





Commodity Fumigation Other FFP Program Areas or Elements Civil society HIV/AIDS Maternal and child health Family planning and reproductive health Water supply and sanitation Environment Climate change – adaptation Climate change - clean energy Nutrition Basic education Social assistance Agriculture Private sector productivity Financial sector Protection, assistance and solutions Disaster readiness

2.0 BASELINE ENVIRONMENTAL INFORMATION2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL) Implementing partners are expected to design their programs to address intervention area-specific biophysical, socioeconomic and cultural conditions, as well as the political and institutional context in which the development food security activities will operate. Applicants are expected to draw from existing USAID or other country-level environmental analyses, including the 2013 West Africa Environmental Threat and Opportunity Assessment (ETOAs), Climate Change Vulnerability and Adaptation Analyses, Foreign Assistance Act (FFA) 118/119 Biodiversity and Tropical Forestry Assessments, and Country Specific Information reports.

The following sub-sections provide a brief overview of the baseline climate and environmental information for Burkina Faso and Niger.

Burkina Faso Environmental ContextNiger Environmental ContextBurkina Faso PERSUAP and PesticidesNiger PERSUAP and PesticidesBurkina Faso Invasive SpeciesNiger Invasive SpeciesBurkina Faso Water QualityNiger Water Quality

BURKINA FASO ENVIRONMENTAL CONTEXT


According to the Climate Risks Profile for Burkina Faso, Northern Burkina Faso, the focus of USAID’s Food for Peace (FFP) in-country programming, is a semi-arid region that is chronically food insecure. In this area, poverty, limited rainfall, high evaporation rates, dependence on rain fed crops, and poor soils make people highly vulnerable to climate shocks (such as droughts, floods, heat waves and dust storms) that drive down agricultural production and increase food prices. Climate change has already impacted Burkina Faso, with increased temperature and the arid region spreading further south. Temperatures are expected to increase by an additional 1.6 - 2.8 C by 2050, there will likely be an increase in frequency and intensity of heavy rainfall, and longer dry periods. These changes will exacerbate decreased food security, impacting water resources, agriculture and livestock.

As outlined in the 118/119, priority threats to biodiversity include, 1) deforestation, 2) expansion of agriculture into native ecosystem areas, 3) intensive exploitation and use of water sources, including water pollution, 4) soil degradation and accelerated desertification, 5) unsustainable use of natural resources, 6) unsustainable grazing, 7) poaching, unsustainable hunting and fishing, 8) climate change, 9) large scale and inadequate artisanal mining, and 10) bushfires.

Moreover, Burkina Faso has a high population growth rate (3 percent per year during 2010–20153), pervasive poverty (43.7 percent live on less than $1.90 per day4), a highly rural population (70 percent5) and a heavy reliance on agriculture, which employs more than 80 percent6 of the working population and accounts for about 34 percent7 of GDP. These factors are driving expanded cultivation and extensive, low-input agricultural production, both of which increase pressure on natural resources essential to the country’s mostly rural population.

Additional information on the environment and climate baseline and natural disasters facing Burkina Faso is also compiled by USAID in the October 2017 Food for Peace Food Security Desk Review for Burkina Faso and the Climate Risks in Food for Peace Geographies in Burkina Faso. All relevant threats should be considered by implementing partners in their Activity-level IEEs.

NIGER ENVIRONMENTAL CONTEXTAs outlined in the Climate Risks Profile for Niger, Niger is one of the hottest and driest countries in the world, with a vast part of the country falling within the Sahara Desert and the Sahel. Temperatures are expected to increase by an additional 1.6 -2.9 C by 2050, with increased variability of inter-annual rainfall and increased extreme weather events. High intra- and inter-annual climate variability constrain health outcomes and

3 FAO. 2014. Country Factsheet on Food and Agriculture Policy Trends: Burkina Faso.4 UNDP. 2016. Human Development Report 2016.5 UNEP. 2011. Livelihood Security: Climate Change, Migration and Conflict in the Sahel.6 World Bank. Accessed 2017. Climate Change Knowledge Portal: Burkina Faso.7 World Bank. Accessed 2017. Burkina Faso Country Profile.


water resources and contribute to chronic food insecurity such that food production does not meet consumption even in good years.

Crop production (mainly millet, sorghum and cowpea) is predominantly rain fed and reliant on the region’s low and highly variable rainfall, making it extremely vulnerable to climate variability and change. Climate trends could negatively impact productivity in the FFP zones. These include increasing temperatures, heat wave duration and evaporation along with heavy rainfall and potentially increased rainfall variability. In addition to harsh climate conditions, declining soil fertility and high increasing population pressure on arable land challenge crop production. Agriculture accounts for roughly 40 percent of gross domestic product (GDP) and is the principle source of livelihoods for more than 80 percent of the population.8

The livestock sector accounts for 14 percent of the country’s GDP and 40 percent of the agriculture sector’s contribution to GDP. While typically more resilient to climate variability and shocks than crops, livestock are susceptible to heat stress and production is affected by rangeland productivity, feed production, water availability and pest and disease dynamics. Drought is the most significant risk in livestock production, and in combination with other shocks, led to major sector losses in recent decades. In 2009–2010, drought followed by heavy rains and flooding led to estimated losses across agro pastoral and pastoral zones of 26 percent of cattle, 39 percent of sheep, 31 percent of goats and 3 percent of camels.9 Drought also aggravates mortality and morbidity by altering livestock disease dynamics, triggering food price spikes and increasing conflicts over rangeland and water resources. In addition to drought shocks, projections for more variable rainfall and more severe dry seasons could lead to rangeland degradation and loss of grazing potential.

BURKINA FASO PERSUAP AND PESTICIDESAccording to the Climate Risks Profile for Burkina Faso, chemical pesticide use is generally low in Burkina Faso, with most of the pesticides applied to cotton and other high-value crops, mainly in the south. Banned pesticides containing dieldrin, endosulfan and heptachlor and restricted pesticides containing HCH, lindane and monocrotophos; however, are available to farmers in parts of the Sahel. Pests and diseases cause significant agricultural damage every year and it is possible that farmers will respond by increasing pesticide use.

The adverse impacts of climate stress on agricultural production could also incentivize farmers to increase pesticide use. Increased frequency and intensity of heavy rainfall, meanwhile, could reduce pesticide effectiveness and increase pesticide contamination. More than 180 herbicides, insecticides and fungicides are used in the country, many of them not authorized for sale. Risk of pesticide contamination in soils and surface water and groundwater is high given weak regulations on pesticide use, lack of awareness regarding safe use (and lack of labeling about safe and effective use), and poor soils

8 World Bank. 2013. Agricultural Sector Risk Assessment in Niger.9 Ibid.


that lead to high rates of water runoff during heavy rainfall events. Pesticide contamination causes poisoning in people and can have adverse ecological impacts.

Most pesticide use is related to cotton production, with limited quantities used in subsistence farming. All of these impacts and factors should be considered in an Activity-level IEE. FFP activities in Burkina Faso should develop a tiered-off Safer Use Action Plan (SUAP) from the PERSUAP that is specific to the activity. See below on PERSUAPs for more information on pesticide use, e.g. fumigation, agriculture, livestock, and construction.

NIGER PERSUAP AND PESTICIDESAs stated in the Climate Risks Profile for Niger chemical pesticide use is generally low in Niger, however, herbicide use in particular is increasing across the Sahel. A national survey of 2,200 households in 2011–2012 showed that 7.8 percent used agrochemical pesticides, herbicides and/or fungicides and 17 percent used inorganic fertilizer. Pesticide use poses risks to human and livestock health and has caused respiratory tract problems in humans and poisoning in livestock in the country. Additional risks include minor to acute neurological, immunologic and reproductive effects. Most pesticide use occurs in irrigated areas with limited quantities used in subsistence, rain fed farming. Demand for pesticide use could increase, however, in response to the low level but persistent agricultural damage that occurs from pests and diseases. Farmers could be incentivized to increase pesticide use if climate variability and change bring increased adverse impacts on agricultural production.

Supply-side changes such as increased availability and low-cost pesticides from China and India have also driven increased use in parts of the Sahel. Risk of pesticide contamination in soils and surface water is high, given incomplete or absent pesticide labelling, lack of awareness about safe and effective use, and poor soils, which lead to high rates of water runoff during heavy rainfall events. Increased frequency and intensity of heavy rainfall could increase contamination risks and reduce pesticide effectiveness. All of these impacts and factors should be considered in the IEE and a PERSUAP should be developed. FFP activities in Burkina Faso should develop a tiered-off SUAP from the PERSUAP that is specific to the activity. See below on PERSUAPs for more information on pesticide use, e.g. fumigation, agriculture, livestock, and construction.

BURKINA FASO INVASIVE SPECIESAccording to the Climate Risks Profile for Burkina Faso, invasive species are often highly adaptable and can respond positively to rising temperatures and variable climate conditions. Some initiatives have even promoted certain invasive species because of these very characteristics, to the detriment of land productivity, biodiversity and ecosystem function. Guidance from the Bureau for Democracy, Conflict, and Humanitarian Assistance (DCHA) Environmental Officer specifically prohibits USAID support for promotion of any invasive species. Many invasive plants are early-maturing and may thus capture a larger share of nutrients, water and


pollinators, outcompeting crops and native species. Additionally, invasive species can often establish in degraded lands. Converting native vegetation to agricultural land disturbs the soil and disrupts plant communities, giving invasive species an opportunity to proliferate. Problematic invasive species reduce crop and livestock production, displace native biodiversity and increase production costs. Although specific information on invasive species in northern Burkina Faso is lacking, anecdotal evidence suggests that Chromolena odorata and Eichorniae crassipes (water hyacinth) already threaten grasslands, shrub lands, savannahs, dry forests, rivers and wetlands. Some species known to be present in Burkina Faso are:

o Prosopis juliflora: Perennial, deciduous, fast-growing, nitrogen-fixing and very salt- and drought-tolerant shrub or tree with deep tap roots; grows in arid and semi-arid environments, forms dense stands and outcompetes native vegetation. Has shown increased distribution under increasing temperature and long dry periods in Kenya which may present an issue in Burkina Faso.

o Chromolena odorate: Perennial shrub; forms dense thickets; competes with crops and native species; presents fire risk during the dry season. Highly adaptable to variable rainfall in the range of 600–2,000 mm.

o Eichorniae crassipes: (water hyacinth) Aquatic species of a few centimeters to over a meter in height; forms dense floating mats that impede water flow and create mosquito breeding areas. Adapted to temperature range of 12-35C, seeds can germinate in a few days or remain dormant for 15-20 years to survive variable conditions.

NIGER INVASIVE SPECIESIncluded in the Climate Risks Profile for Niger, problematic invasive species reduce crop and livestock production, displace native biodiversity and increase production costs. Specific information on invasive species in Niger is lacking a few invasive plant species have been recognized including various Prosopis juliflora, Eichorniae crassipes (water hyacinth), Cyperus rotundus and non-native Acacia species, are a risk to grasslands, shrublands, savannahs and wetlands. The species known to be present in Niger are:

o Prosopis juliflora: Perennial, deciduous, fast-growing, nitrogen-fixing and very salt- and drought-tolerant shrub or tree with deep tap roots; grows in arid and semi-arid environments, forms dense stands and outcompetes native vegetation Has shown increased distribution under increasing temperature and long dry periods in Kenya which could pose a problem in Niger in the future.

o Eichorniae crassipes: (water hyacinth) Aquatic species of a few centimeters to over a meter in height; forms dense floating mats that impede water flow and create mosquito breeding areas. Adapted to temperature range of 12-35C, seeds can germinate in a few days or remain dormant for 15-20 years to survive variable conditions.

o Cyperus rotundus: Sedge species of about 30 cm with a smooth, grass-like appearance; perennial weed with extensive underground tuber and root system; one of the world’s worst invasive weeds based on its distribution and effect on


crops. Adapted to high temperatures and solar radiation; performs well with elevated levels of CO2, suggesting it may become more invasive in the future.

Further information about climate impacts on agriculture in the Sahel can be found in this report: Agricultural Adaptation to Climate Change in the Sahel: Expected Impacts on Pests and Diseases Afflicting Crops.

BURKINA FASO WATER QUALITY The British Geological Society showed concentrations of arsenic in Burkina Faso in the Ouahiguoya area had a large range (<0.5–1630 µg/L) although most analyzed samples contained less than 10 µg/L. There was a large spatial variability in arsenic concentrations, these high concentrations are derived from zones of gold mineralization in ancient volcano-sedimentary rocks. The source stated by the BGS is likely to be oxidized sulphide minerals and secondary iron oxides. Some solutions to these levels of arsenic would be to decommission problematic wells and provide alternative supplies as well as consistent and detailed testing of the water in the wells. Another study focused on the water quality in rural Burkina Faso that tested water from boreholes. It was stated that some water tested had high nitrates or sulfate concentrations over the WHO guidelines as well as microbiologically polluted. It was also mentioned that turbidity and PH can also be of concern for tested water from Burkina Faso.

Water quality assurance is essential for food security in Burkina Faso. It is important that each activity develops Water Quality Assurance Plans (WQAPs) following latest guidance put out by USAID. The importance of the WQAP is to establish a plan for water quality testing, as well as establish a plan of action if contamination is identified. Testing alone does not identify the necessary local or internationally accepted protocol for addressing sources of contamination that may be identified.

NIGER WATER QUALITYThe African Development Bank Report on Rural Drinking Water Supply and Sanitation Project states that The River Niger is the source of permanent water for much of Niger while renewable groundwater harnessing has been low. This groundwater in the Maradi region is in continuous sedimentary aquifers, which are often very deep or discontinuous, as well as difficult to access. These sedimentary aquifers are often very extensive and going beyond the borders of the country. There are various hydrographic formations that influence the quality of the groundwater such as fragmented aquifers, continuous aquifers, and aquifers in valley alluvial formations. The British Geological Society states that basement wells are in need of testing for levels of arsenic. Levels of arsenic, lead and uranium were found in borehole water sources in Niger in a study focused on borehole water testing.

Water quality assurance is essential for food security in Niger. It is important that each activity develops Water Quality Assurance Plans (WQAPs) following latest guidance put out by USAID. The importance of the WQAP is to establish a plan for water quality


http://www.usaidgems.org/wqap.htm

https://www.afdb.org/fileadmin/uploads/afdb/Documents/Project-and-Operations/Niger_-_Rural_Drinking_Water_Supply_and_Sanitation_Project_in_the_Regions_of_Maradi__Tahoua_and_Tillaberi_-_Appraisal_Report.pdf

https://www.afdb.org/fileadmin/uploads/afdb/Documents/Project-and-Operations/Niger_-_Rural_Drinking_Water_Supply_and_Sanitation_Project_in_the_Regions_of_Maradi__Tahoua_and_Tillaberi_-_Appraisal_Report.pdf

http://www.usaidgems.org/wqap.htm

http://file.scirp.org/Html/4-6701692_27177.htm

http://www.bgs.ac.uk/research/groundwater/health/arsenic/BurkinaFaso.html

testing, as well as establish a plan of action if contamination is identified. Testing alone does not identify the necessary local or internationally accepted protocol for addressing sources of contamination that may be identified.

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS (E.G. WHO), ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS

SUB-SAHARAN AFRICA EIA PROCEDURESAccording to the Legal and Regulatory Framework Study of the World Bank, environmental impact assessment, or EIA as it is known, is a procedures for evaluating the impact, proposed activities may have on the environment. In recent years, significant strides have been made to build a legal foundation for EIAs in Sub-Saharan Africa. Whereas EIAs typically used to be carried out only to meet requirements of foreign donors, they are now mandated in twenty-two Sub-Saharan countries, as an important element of domestic environmental law, and policy. Activities for Burkina Faso and Niger are expected to understand and document their compliance with local EIA regulations in their Activity-level IEEs.

BURKINA FASO REGULATORY STRUCTUREBurkina Faso accounts several laws, policies and strategies around the Legal Framework affecting conservation and forestry. The most relevant laws and policies are described on an IUCN report called “An IUCN situation analysis of terrestrial and freshwater fauna in West and Central Africa”. The report identifies and describes the main institutional laws, policies, and strategies regulating the country’s aim to conserve and search for sustainability. The country is also a member on several international agreements, treaties and conventions such as: Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), United Nations Framework Convention on Climate Change (UNFCCC), and United Nations Convention to Combat Desertification (UNCCD) just to name a few. More detailed information can be found in the FAA 118/119 for Burkina Faso.

Law No. 006-2013/AN (Loi n°006-2013/AN portant code de l’environnement du Burkina Faso) of 2 April 2013 provided the Environmental Code of Burkina Faso and repealed Law No. 005/97/ADP (Loi nº 005/97/ADP portant Code de l’environnement au Burkina Faso) of 30 January 1997. The new Environmental Code aims to protect people against the threats caused by the degradation of their environment and to improve living conditions. It states that promoting a healthy environment is of general interest and the responsibilities of all individuals. It further states that maintaining environmental quality and the restoration and enhancement of natural resources must be based on the principles of participation and public information, prevention, precaution, polluter pays, sustainable development, and subsidiarity. It recognizes the rights of local populations, civil society, and the private sector to participate in the management of their environment and it enshrines a right to use natural and genetic resources for local people and the sharing of benefits arising from their exploitation.


http://www.usaidgems.org/118119/faa118119Africa.htm

https://elibrary.worldbank.org/doi/abs/10.1596/0-8213-5115-X

Burkina Faso’s resilience to climate change is guided by the country's 2015 National Adaptation Plan (NAP), which aims to “(i) reduce vulnerability to the impact of climate change by developing adaptation and resilience capabilities; (ii) facilitate the integration of climate change adaptation into new or existing policies, programmes or activities and in specific development planning processes and strategies in pertinent sectors and at various levels in a coherent manner.” In addition, the Second National Communication of Burkina Faso on Climate Change to the United Nations Framework Convention on Climate Change (UNFCCC) highlights climate mitigation commitments of the country and sector specific climate risks and adaptation measures.

NIGER REGULATORY STRUCTUREThe Rural Code is a key element of the Nigerian national policy on rural land tenure and the management of natural resources. It hinges on a legal system (composed of all the rules and regulations concerning land tenure and natural resources management) and an institutional system (a group of institutions that implement and monitor those rules). The two systems apply at different levels, from the local level to the national one. The Rural Code consists of a series of legal texts; the 1993 ordinance (ordonnance cadre) containing its guiding principles and sector-specific legislation. At the national level, the National Committee of the Rural Code defines global policy guidelines for the State. It is chaired by the Ministry of Agriculture and includes other ministries involved in the management of land and natural resources.

The rural agricultural zone is the part of the national territory located south of the limit for cultivation as defined by the 1961 Law. The private property system applies to this area. Land property can be acquired through custom or positive law. When no ownership rights can be established, the land is considered vacant and belongs to the State or to decentralized local institutions. The Ministry of Agriculture (Ministère de lÁgriculture) is responsible for the preparation, implementation, and monitoring of the national policy on agricultural development.

The rural pastoral zone is the part of the national territory located north of the limit for cultivation defined also by the 1961 Law. It belongs to the State. The rights of pastoralists (who own or keep cattle) include free access to natural resources in the pastoral zone, they hold a common use right for this zone. Ministry of Livestock (Ministère de lÉlevage du Niger) ensures the development and promotion of livestock through the design, development, and implementation of the national policy for productions development, the animal industries, and the national animal health policy.

Water is a strategic resource and constitutes State property. Rivers, lakes, ponds, sources, and groundwater are therefore considered State property. The Ministries of Environment and Water (Ministère de l´Hidraulique et de lÉnviornnement) are responsible for the design, development, implementation, and monitoring and evaluation of national environment and water policies and combating desertification. They are specifically responsible for defining and implementing policies and strategies relating to water, forest, wildlife, fisheries, and apiculture resources.


Although Niger is a signatory of many international treaties, including Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and Convention on Biological Diversity (CBD), the country’s capacity to implement treaty or convention agreements is weak due to a lack of information given to key government stakeholders and a lack of resources. Commonly, government agencies look to NGOs or cooperation agencies to collaborate and/or coordinate activities and actions related to treaties/conventions. More detailed information can be found in the FAA 118/119 for Niger.

To limit the impacts of climate change to Niger, the country’s National Adaptation Plan (NAP is being developed, as highlighted by the ‘stocktaking activity and recommendations’ conducted in 2014 to prepare for the NAP. Niger released their Second National Communication on Climate Change to the UNFCCC in 2009 and their Third National Communication on Climate Change in 2016. These documents guide climate change mitigation commitments from the country, and highlight climate change adaptation needs.

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISKCOMMODITY FUMIGATIONMost FFP activities will carry out the storage and protection of commodity, either as US in kind food assistance or as locally-procured food commodity. To prevent the loss of food commodity from pest infestations during storage, it is common practice to perform periodic fumigation of warehouses and/or the application of contact pesticides to warehouse surfaces.

As mentioned in the Fumigation PEA, impacts of commodity fumigation must be considered, including:

o Use of the fumigant aluminum phosphide, and to a lesser extent magnesium phosphide, can potentially affect the health of applicators and other on-site workers and visitors.

o Use of the fumigant phosphine gas can affect the health of residents near warehouses being fumigated.

o The quality of the food commodity may be compromised due to phosphine fumigation.

o Beneficiary populations may be at risk from inhalation, preparation, and ingestion of fumigated commodities.

o Fumigation residuals could affect water quality, soil, and non-target organisms.o Poor practices in transport, storage, and disposal of fumigants are a concern for

human health.o Improper disposal practices of rodents and birds killed by phosphine gas could

affect human health.o Phosphine may not completely control fungal contamination.


http://www.usaidgems.org/118119/faa118119Africa.htm

In addition, it is a USAID agency commitment that activities consider the procurement or promotion of pesticides as a last resort within an Integrated Pest Management (IPM) framework (see USAID Special Topic Presentation on Pesticides). Whichever their intended use may be, pesticides are potent killing agents and their use poses intrinsic dangers to applicators, households, communities and the environment. These risks include, but are not limited to:

o Use of chemical, non-organic compound-based, and biological or botanical-based pesticides can potentially affect the health of applicators, on-site workers and visitors.

o Poor practices in the transport, storage, and disposal of pesticides and pesticide containers are a concern for human and environmental health.

o Pesticides can negatively affect and/or eliminate non-target organisms in the environment, (i.e. predatory insects and pollinators, microorganisms beneficial to soil health, aquatic organisms, etc.) thereby altering ecological food webs and potentially causing detriment to agricultural production systems.

o Chemical pesticides can contaminate surface and groundwater water, soils, and can bioaccumulate in surrounding ecosystems and organisms, posing a concern for health.

o Misuse or overuse of pesticides can result in pesticide-resistance.

TABLE 2. POTENTIAL IMPACTSCommodity Fumigation Potential environmental and social impactsWarehouse treatment of bagged and bulk commodity

Treatment of empty warehouse with contact pesticides

● Health of applicators and on-site workers and visitors (including transporters)

● Health of nearby residents● Commodity quality● Health of beneficiaries● Water quality, soil, and non-target organisms● Solid waste management ● Disposal of dead birds and rodents● Fungal diseases

OTHER FFP PROGRAM AREAS AND ELEMENTSThis RFA IEE cannot determine the reasonably foreseeable potential environmental impacts of interventions within the FFP Program Areas and Elements described in Section 1.3, as the scope and technical approach of these interventions have not yet been defined. These interventions will be more refined and analyzed in Activity-level IEEs.

4.0 ENVIRONMENTAL DETERMINATIONS 4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONSA Positive Determination, pursuant to 22 CFR 216.3(b)(l)(iii), is recommended for all commodity fumigation activities.

A Deferral is recommended for all other activity interventions that are not yet well defined in scope or technical approach pursuant to 22 CFR 216.3(a)(7)(iv). The


Deferral for these interventions, or FFP program elements, must be resolved in the post-award Activity-level IEE, in which each intervention will be assigned a threshold determination: Categorical Exclusion, Negative Determination with Conditions or Positive Determination.

The following table summarizes the recommended determinations based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22 CFR 216.

TABLE 3: ENVIRONMENTAL DETERMINATIONS

Illustrative Interventions

Categorical Exclusion Citation (if applicable)

Negative Determination

Positive Determination Deferral

Commodity Fumigation XOther FFP Program Areas and Elements X


4.2 CLIMATE RISK MANAGEMENTIt is recommended that Climate Risk Management screening begins at the supplemental Activity-level IEEs for Other FFP Program Areas and Elements. These activity interventions have not yet been well defined in scope or technical approach, and therefore it is appropriate to begin Climate Risk Management screening when they are better defined, pursuant to Climate Risk Management for Projects and Activities. A Mandatory Reference for ADS 201. It is likely that many of these interventions will have high climate risks during implementation. Climate Risk Management screening for these activities must be resolved in the post-award Activity-level IEE, in which climate risks, and opportunities to integrate climate into programming, will be identified and addressed as outlined by USAID and FFP Climate Risk Management policy and guidance. Other Climate Risk Management screening, such as the screening done for the RISE II USAID Project, can be used for examples. Climate Risks Management Screening for Commodity Fumigation, was completed below.

Burkina Faso and Niger both have increasing temperatures, changing rainfall patterns, and potential increases in humidity in some regions, all of which could impact the effectiveness of pesticides used for fumigation. Furthermore, changing environmental conditions can lead to changes in herbivore and pathogen range and occurrence, which should also be considered during fumigation. Changing pests and pathogen distribution can have a large impact across agricultural value chains, as highlighted in the Burkina Faso and Niger and Climate Risks Profiles.

Based on an analysis identifying the impacts of climate change and variability on commodity fumigation, summarized in Table 5, both low, moderate, and high climate risks were identified. The following climate risks were identified as medium risk to project implementation:

o Climate change, such as increased temperatures and changes in rainfall patterns, changes occurrence of pests and pathogens and therefore fumigation requirements.

o Warehouses where commodities are stored are in locations threatened by extreme weather, or in flood zones.

To limit these risks, the following actions were identified:

o Conduct review of relevant literature on how pests and pathogens will change in the area due to climate change and evaluate how that might impact commodity storage and fumigation.

o Ask local community members about observed changes in pathogen and pests over recent years, and use fumigation that is relevant for the current situation.

o During site selection evaluate if storage facilities are in areas that are exposed to extreme weather or regular flooding.


https://www.climatelinks.org/sites/default/files/asset/document/2017_USAID%20ATLAS_Climate%20Risks%20in%20Food%20for%20Peace%20Geographies%20Niger.pdf

https://www.climatelinks.org/sites/default/files/asset/document/20170807_USAID%20ATLAS_FFP_BurkinaFaso.pdf

TABLE 5. CLIMATE RISK MANAGEMENT SUMMARY TABLEDefined or Anticipated Program Intervention

Timeframe Geography Climate Risks

List key risks related to the activity intervention identified through either the strategy- or project-level climate risk assessment.

Risk Rating

Low/Moderate/ High

Climate Risk Management Options

How are risks addressed

Opportunities to Strengthen Climate Resilience

Describe opportunities to achieve development objectives by integrating climate resilience or mitigation measures.

Commodity Fumigation

Life of the award, until 2023.

Areas where commodity fumigation will occur. Likely country-wide.

Increased temperatures reducing effectiveness of fumigation

Low N/A N/A Educate local communities, including farmers and agribusiness about potential changes in pest and pathogen distribution due to climate change and provide techniques to limit the impact of these changes throughout the agricultural value chain

Changes in humidity reducing fumigation effectiveness

Low N/A N/A

Climate change, such as increased temperatures and changes in rainfall patterns, resulting in

High Conduct review of relevant literature on how pests and pathogens will change in the area due to climate change

Conduct review of relevant literature on how pests and pathogens will change in the area due to


changes in occurrence of pests and pathogens and therefore fumigation requirements.

and evaluate how that might impact commodity storage and fumigation. Ask local community members about observed changes in pathogen and pests over recent years, and use fumigation that is relevant for the current situation.

climate change and evaluate how that might impact commodity storage and fumigation. Ask local community members about observed changes in pathogen and pests over recent years, and use fumigation that is relevant for the current situation.


5.0 CONDITIONS AND MITIGATION MEASURES5.1 CONDITIONSFor applicants, USAID FFP environmental compliance at the time of activity design will be met through adherence to both 1) this RFA IEE and 2) completion of a stand-alone, Activity-level IEE, only upon USAID’s indication of an intent to award. Once the Activity-level IEE, including the Environmental Mitigation and Monitoring Plan (EMMP) and attendant budget, is finalized and approved by the DCHA BEO, the IEE is to be used to guide activity implementation. All mitigation measures contained in the Activity-level IEE must be implemented and monitored for effectiveness in reducing potential environmental impacts resulting from interventions.

The following 8 conditions describe awardees’ environmental compliance, mitigation, monitoring and evaluation responsibilities throughout the life of award (LOA).

The environmental determinations in this IEE are contingent upon these general implementation and monitoring requirements, as well as ADS 204 and other relevant requirements.

5.1.1 DURING PRE-AWARD STAGE

CONDITION 1: DEVELOP ENVIRONMENTAL SAFEGUARDS PLANUSAID requires analyses which consider environmental risks across the Agency, using a set of defined procedures to meet USAID environmental requirements. Applicants are expected to design innovative approaches to promote environmental risk management to improve and sustain food and nutrition security of vulnerable populations, as articulated in both SO1 and SO2 of the FFP 2016-2025 Food Assistance and Food Security Strategy. Applicants must summarize these environmental approaches into a four-page Environmental Safeguards Plan.

This plan must summarize:

1. How both strategies reduce climate risks to the activity and environmental impacts of the activity have been integrated into activity design;

2. How funds for environmental risk management have been allocated in the detailed/comprehensive budgets and described in the budget narrative;

3. How outcomes of the EMMP will inform the performance monitored through the Log Frame and IPTT in M&E systems;

4. How staffing capacity for oversight of environmental compliance requirements will be carried out over the life of the activity.

5.1.2 DURING POST-AWARD STAGE

CONDITION 2: DEVELOP ACTIVITY-LEVEL IEE, CRM SCREENING AND EMMP

22 USAID/DCHA FFP FY18 RFA IEE

https://www.usaid.gov/FFPStrategy

https://www.usaid.gov/FFPStrategy

https://www.usaid.gov/ads/policy/200/204

Upon receipt of the FFP award, implementing partners will be required to develop an Activity-level IEE to provide environmental impact analysis for all interventions. In short, the Activity-level IEE must 1) sufficiently describe the technical design of all interventions, 2) identify all reasonably foreseeable environmental impacts of interventions, and 3) recommend sound mitigation measures to prevent, reduce or compensate for environmental impacts. There are many important resources that partners can consult when developing Activity-level IEEs.

o For a general introduction on how to develop an IEE, consult the USAID IEE Assistant.

o Partners are advised to consult previous Activity-level IEEs to research common environmental concerns and solutions among FFP activities globally. Partners can utilize the USAID Environmental Compliance Database to search for USAID-approved IEEs.

o For technical guidance on environmentally sound design and management for USAID development activities, consult the USAID Sector Environmental Guidelines.

o The USAID Global Environmental Management Support (GEMS) website contains detailed guidance and best-practice considerations for the development of the EMMP.

o The USAID Environmental Compliance Budgeting Toolkit provides partners with guidance on how to identify costs for environmental management tasks described in the Activity-level IEE and EMMP.

o Climatelinks is a global knowledge portal for those working at the intersection of climate change and international development.

As an annex to all Activity-level IEEs, FFP applicants must complete an EMMP which serves as the implementation and monitoring plan for all required 22 CFR 216 compliance actions to be taken by a given activity. This RFA IEE provides a template for the EMMP in the annexes. Detailed guidance and best-practice considerations for the development of the EMMP is available on the USAID Global Environmental Management Support (GEMS) website and in the Environmental Mitigation and Monitoring Plan Factsheet. The effectiveness of the individual compliance actions (mitigation measures) to prevent or reduce environmental impacts must be monitored periodically throughout the life of the activity. The results of this monitoring should be described in the annual ESR. See information below.

Upon receipt of the award, the partners will also develop a Climate Risk Management screening for all activities. The purpose of the Climate Risk Management screening is to identify and address climate risks and opportunities for all new USAID activities. The Climate Risk Management screening will be submitted with the Activity-level IEE. Guidance to conduct Climate Risk Management screening can be found in the annexes.

Timing: Awardees must develop a draft of the IEE in advance of the M&E Workshop for use in coordination of EMMP and performance M&E systems. Awardees will then


https://www.climatelinks.org/about

refine this draft IEE and submit the IEE, CRM screening, and EMMP within approximately 60 days following the M&E Workshop. This submission date will permit the necessary updating to the draft analyses with any updated structure of the Logical Framework, etc.

The BEO Decision Memo: This is a short decisional memo appended to each submitted IEE, ESR, PERSUAP and EA that indicates final DCHA/BEO approval of the given compliance documentation, and describes any required conditions that must be met by the implementing partner. Upon approval and attachment of the Decision Memo, all environmental compliance documentation is subsequently shared with the implementing partner and uploaded to the publicly accessible Environmental Compliance Database. Activity-level IEE must be approved by the USAID DCHA Bureau Environmental Officer (BEO) prior to the implementation of medium-risk interventions (i.e., classified as a Negative Determination with Conditions as per 22 CFR 216).

CONDITION 3: DEVELOP AN ENVIRONMENTAL ASSESSMENT FOR ACTION WITH SIGNIFICANT EFFECT, AS DETERMINED BY USAID

Increasingly, FFP partners have been responding to the need to develop more significant physical infrastructure to meet food security demands. For activities with potential for significant environmental effect, USAID may require partners to complete a full environmental impact assessment process.

A Positive Determination, pursuant to 22 CFR 216.3(a)(2)(iii) or 22 CFR 216.5, may arise if an interventions determined as a Deferral by this RFA IEE is later identified as having the potential to cause significant environmental effect. Interventions that receive a Positive Determination will require further analysis, such as a Scoping Statement and Environmental Assessment. The following classes of actions have been determined generally to have a significant effect:

o Programs of river basin development;o Irrigation or water management projects, including dams and impoundments;o Agricultural land leveling;o Drainage projects;o Large scale agricultural mechanization;o New lands development;o Resettlement projects;o Penetration road building or road improvement projects;o Powerplants;o Industrial plants;o Potable water and sewerage projects other than those that are small-scale.

Additionally, if the proposed activity will have the effect of jeopardizing an endangered or threatened species or of adversely modifying its critical habitat, the Threshold Decision is a Positive Determination.


https://www.usaid.gov/our_work/environment/compliance/22cfr216

CONDITION 4: INTEGRATE ENVIRONMENTAL CONSIDERATIONS, INCLUDING CLIMATE RISKS, INTO M&E SYSTEMSA key component of environmental safeguards for USAID activities is to ensure the inclusion of climate risk and environmental considerations into activity performance monitoring systems. For FFP, to promote ongoing safeguards for environmental goods and services while achieving food assistance and security gains, applicants will need to integrate environmental considerations into the overall activity M&E systems.

The Monitoring and Evaluation (M&E) workshops, held at the start-up of new FFP development food security activities, are designed to convey M&E requirements and to strengthen awardees’ Logical Frameworks and Indicator Performance Tracking Tables (IPTTs). During these workshops, awardees have an opportunity to work with M&E experts to coordinate the IPTT with the EMMP.

As described in the Policy and Guidance for Monitoring, Evaluation, and Reporting of Development Food Security Activities, awardees may make other additions to clarify the use of a FFP or Mission indicator in the activity’s M&E Plan. For example, text may be added to the Rationale section to identify the indicator as part of the activity’s EMMP and explain how the indicator is environmentally sensitive to the activity context.

Clarifications inserted into the PIRSs, like those described above, do not ‘change’ the FFP or Mission indicator; they simply add more information about how the indicator will be collected and which activities beneficiaries or Outputs will be considered.

CONDITION 5: ENSURE A SUFFICIENT AND TRANSPARENT ENVIRONMENTAL COMPLIANCE BUDGETA budget for the implementation of the IEE and EMMP must be transparently demonstrated in the Detailed and Comprehensive Budget and Budget Narrative for the award. Budget must be included for IEE implementation, such as for internal staffing, technical support, training, monitoring/reporting, pesticide expertise, as well as, for any Environmental Assessments that arise from a Positive Determination classification of risk.

The budget for environmental compliance must not exceed the Total Estimated Cost (TEC) of the multi-year activity. Rather this compliance budget must be allocated from within the award TEC. Failure to do so in a transparent manner, will result in delays. The budgeting for environmental compliance is to be reviewed in the beginning of the activity, and annual with the PREPs. Refer to the USAID Environmental Budgeting Toolkit for step-by-step guidance for both budget developers and USAID budget reviewers.




*Note: It may be possible to combine Steps 3 and 4 into a single step, depending on the particular budgeting process. It is shown here as two separate steps for greatest clarity.

Figure 1: Developing Activity Budgets for Environmental Compliance Requirements.

Source: Adapted from Environmental Compliance Budgeting Toolkit, p. 5.


4. Integrateenvironment al costs into

activity budgets and narratives.

3. Translateenvironment

al costs of Step 2 into

standard FFP budget

categories.*

2. Quantifyenvironmental

costs identified in Step 1.

1. Identifymaterials and

services needed to implement

environmental requirements.

CONDITION 6: PLAN FOR A PESTICIDE EVALUATION REPORT AND SAFE USE ACTION PLAN (PERSUAP) 6A. Commodity fumigation mitigation requirements

USAID requires that the person/people carrying out commodity fumigation operations hold official certification to perform the fumigation, use fumigants according to the directions on the product label, and follow all listed directions, precautions, and restrictions. Fumigants will be used only for commodities and at sites specified by the product label.

USAID has developed an assessment of environmental and health risks in the fumigation of food assistance commodity entitled USAID Programmatic Environmental Assessment (PEA) for Phosphine Fumigation of Stored Agricultural Commodity. The PEA includes a Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) template, and a Fumigation Management Plan (FMP) template. These tools are intended to assist in compliance with the Fumigation PEA’s requirement for completion of an activity-specific PERSUAP and FMP reporting. The Fumigation PERSUAP should be developed as soon as the warehouse and fumigation service providers are identified, and in advance of the need for fumigation. It is preferred that this PERSUAP be submitted with the Activity-level IEE, if possible. Specific mitigation requirements for the fumigant phosphine are provided in the Fumigation PEA.

Please note that TOPS has released their Warehouse Staff Safety Guide (November, 2014) which is an excellent resource to assist awardees in the design of education campaigns for warehouse commodity storage. The Warehouse Safety Guide posters, which highlight best fumigation practices, are in compliance with the findings of the Fumigation PEA, and compliments the PEA with practical guidance, information, recommendations and tools to promote warehouse staff safety and prevent injury and illness. The materials include an 80-page manual, 7 Warehouse Staff Safety Posters, a 2-day Facilitator’s Training Tool, and various other tools and checklists to help organizations adhere to minimum safety standards in the warehouse. The Guide was funded by USAID through a TOPS Program Micro-grant and developed by Project Concern International (PCI) and the TOPS Commodity Management Task Force.

6B. PERSUAPs for other pesticide use (e.g. agriculture, livestock, public health, construction)

FFP partners must take note that pursuant to 22 CFR 216.3(b ) , in the event that any interventions include the promotion, procurement, transport, storage or disposal of pesticides for agricultural or livestock interventions, vector control interventions, or construction material treatment, a PERSUAP for proposed pesticides must be approved by the DCHA/BEO prior to the commencement of these interventions. PERSUAPs should be submitted with Activity-level IEEs (or as amendments to


Activity-level IEEs). For more information on USAID environmental compliance policy requirements related to pesticides, and PERSUAPs, see this Special Topic Presentation.

Tiering off of Existing Mission PERSUAPs: As soon as interventions in which the procurement or promotion of pesticides are anticipated, it is recommended that awardees contact their Mission Environmental Officer (MEO) to inquire whether an existing PERSUAP has been developed in the country or region that provides the requisite approval and guidance for the use of a particular pesticide or series of pesticides. FFP encourages its awardees to tier off existing USAID analyses when possible, thereby reducing the need to carry out new and potentially redundant analyses, yet allowing for the appropriate consideration of the specific needs and context of each development food security activities. In this case, the FFP activity will need to develop a Safe Use Action Plan (SUAP). The SUAP provides a succinct, definitive stand-alone statement of compliance requirements, synthesized from the 12- factor analysis. It also assigns responsibilities and timelines for implementation of these requirements.

CONDITION 7: MONITOR AND REPORT ON USAID ENVIRONMENTAL COMPLIANCEEnvironmental Status Report (ESR)10: ESRs (known often as Environmental Mitigation and Monitoring Report or EMMR elsewhere in USAID) must be completed by all FFP awardees on an annual basis and submitted to USAID ideally at least three (3) months before the anticipated PREP submission by the partners. The ESRs will be submitted with the M&E Plan updates. The ESR is meant to:

1. Document environmental safeguard staffing and budget for the upcoming implementation year; and

2. Identify progress towards achieving environmental compliance, including a report out on the EMMP monitoring.

The ESR Guidance (see template in the annexes or latest versions here) provides instruction to awardees on what information must be included in the ESR.

EMMP Checklists for Field Monitoring: EMMP checklists can be useful tools to assist implementing partner staff in the integration of environmental management issues in the planning, design and interventions implementation and monitoring phases. EMMP checklists can be designed for rapid environmental diagnostic exercises, which aim to identify site-specific environmental conditions that may lend to the generation of localized impacts. This analysis can be used to determine the most appropriate environmental management strategies on a site-specific basis. For monitoring purposes, checklists can also be designed to facilitate the data collection and monitoring of EMMP indicators.

10 The ESR is similar to the Environmental Mitigation and Monitoring report (EMMR) used elsewhere in USAID. However, the ESR meets both purposes of reporting and budget planning for environmental compliance.


http://www.usaidgems.org/Assistant/EDTEnvironmentalStatusReport.htm

One such example of site field monitoring tools are the GEMS Visual Field Guides, which are intended to support field monitoring of select interventions by development professionals, including those who are not environmental specialists. They are photo-based, simple yes-no checklists that identify the most typical, significant environmental design and management considerations by development sector.

Another example of an environmental monitoring checklist system is the Go Green Strategy (GGS). This scorecard system provides environmental management information in a simple Yes/No checklist, which can be used as a monthly monitoring tool by field agents. This GGS fact sheet can be accessed on the GEMS site. USAID conducted a more detailed assessment of the GGS through a field assessment, as described in the “Examination of Environmental Foundations for Program Design Environmental Compliance Review and Go Green Strategy Snapshot”.

Annual Results Reports (ARRs): Awardees are required to submit an ARR for each FY during which interventions were implemented, regardless of when funding or food assistance commodities were provided. An ARR describes the performance results of interventions implemented during the reporting FY. The ARR should include the results of IPTT environmental and climate change indicators, environmental monitoring reports, assessments, action plans, and/or case studies related to the integration of environmental safeguards and climate change considerations. Please see the FFP ARR Guidance for more information.

USAID Environmental Compliance Site Visits: As required by ADS 204.5.4, the AOR, in consultation with FFP activities, FFP Managers, Mission Environmental Officers (MEO) and/or the DCHA/BEO will actively monitor and evaluate whether environmental consequences unforeseen under interventions covered by this current RFA IEE, and the Activity-level IEEs, arise during implementation and modify or end interventions as appropriate.

IEE Amendments: IEE Amendments: In the event that any new proposed interventions differ substantially from the type and/or agroecological zone of interventions described in a supplemental Activity-level IEE, an IEE Amendment (IEE-A) will be developed, including a revised EMMP. Amendments must be sent to FFP and reviewed for approval by the DCHA/BEO prior to implementation.

Some of the possible triggers for an IEE-A include, but are not limited to: modified or new interventions, new geographic zone, cost extension, and/or significant time extension.

Pursuant to 22 CFR 216.2(b), activities involving international disaster assistance or other emergency circumstances may be Exempt from these procedures. Emergency activities with Agreement Officer approval may be Exempt from environmental review, such as the transfer of food commodities pursuant to 22 CFR 211.


EMMP revisions during the course of implementation, such as fine tuning mitigation measures or including additional analysis for unexpected impacts, are encouraged as part of any activity’s sound adaptive environmental management. It is important to note, such EMMP modifications do not require an IEE amendment, to be approved by USAID. However, all EMMP changes and their rationale, should be reported in subsequent ESRs.

CONDITION 8: ENSURE COMPLIANCE WITH PARTNER COUNTRY REGULATIONSImplementation will in all cases adhere to applicable partner country environmental laws. The Activity-level IEE supports and strengthens the rule of law for systems of environmental governance in partner countries. In order to ensure environmental compliance, the status and applicability of the partner country’s policies, programs, and procedures in addressing natural resources, the environment, food security, and other related issues must be incorporated into each activity. This may include incorporating the national policies pertaining to environmental assessment or other policies related to the sector. Implementing partners must be aware of and ensure compliance to the country’s regulations where their activity is located.

Approved IEEs from the same geographic areas may provide valuable guidance and be a beneficial resource for cross-checking information and developing a deeper knowledge of country-specific regulations and policies. These IEEs are available on the Agency’s Database.


6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION The determinations recommended in this document apply only to activities described herein. Other activities that may arise must be documented in either a separate IEE, an IEE amendment, or other type of environmental compliance document.

Other than activities determined to have a Positive Threshold Decision, it is confirmed that the activities described herein do not involve actions normally having a significant effect on the environment, including those described in 22 CFR 216.2(d).

In addition, other than activities determined to have a Positive Threshold Decision and/or a pesticide management plan (PERSUAP), it is confirmed that the activities described herein do not involve any actions listed below. Any of the following actions would require additional environmental analyses and environmental determinations:

o Support project preparation, project feasibility studies, or engineering design for activities listed in §216.2(d)(1);

o Affect endangered and threatened species or their critical habitats per §216.5, FAA 118, FAA 119;

o Provide support to extractive industries (e.g. mining and quarrying) per FAA 117;

o Promote timber harvesting per FAA 117 and 118;o Lead to new construction, reconstruction, rehabilitation, or renovation work

per §216.2(b)(1);o Support agro-processing or industrial enterprises per §216.1(b)(4);o Provide support for regulatory permitting per §216.1(b)(2);o Lead to privatization of industrial facilities or infrastructure with heavily

polluted property per §216.1(b)(4);o Procure or use genetically engineered organisms per §216.1(b)(1); and/oro Assist the procurement (including payment in kind, donations, guarantees of

credit) or use (including handling, transport, fuel for transport, storage, mixing, loading, application, clean-up of spray equipment, and disposal) of pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials. Pesticides cover all insecticides, fungicides, rodenticides, etc. covered under the Federal Insecticide, Fungicide, and Rodenticide Act per §216.2(e) and §216.3(b).

7.0 REVISIONSPer 22 CFR 216.3(a)(9), when ongoing programs are revised to incorporate a change in scope or nature, a determination will be made as to whether such change


may have an environmental impact not previously assessed. If so, this IEE will be amended to cover the changes. Per ADS 204, it is the responsibility of the AOR to keep the MEO (Abdourahmane N’diaye) and BEO (Erika J. Clesceri) informed of any new information or changes in the activity that might require revision of this environmental analysis and environmental determination.


ATTACHMENTS:

1. ANNEX 1: TEMPLATE FOR ACTIVITY-LEVEL INITIAL ENVIRONMENTAL EXAMINATIONS

2. ANNEX 2: TEMPLATE FOR ENVIRONMENTAL MITIGATION AND MONITORING PLANS

3. ANNEX 3: TEMPLATE FOR ENVIRONMENTAL STATUS REPORTS

4. ANNEX 4: GUIDANCE FOR CLIMATE RISK MANAGEMENTSCREENING


ANNEX 1: TEMPLATE FOR ACTIVITY-LEVEL INITIAL ENVIRONMENTAL EXAMINATIONS

INITIAL ENVIRONMENTAL EXAMINATIONACTIVITY DATA

Activity Name:Amendment (Y/N):Geographic Location(s) (Country/Region):Implementation Start/End:Solicitation/Contract/Award Number:Implementing Partner(s):Link of Other, Related Analyses:


Implementing Operating Unit(s): (e.g. Mission or Bureau or Office)Funding Operating Unit(s): (e.g. Mission or Bureau or Office)Funding Account(s):Funding Amount:Amendment Funding Date:

Amendment Funding Amount:

Other Affected Unit(s):Lead BEO Bureau:Prepared by:Date Prepared:

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: ☐ Initial Environmental Examination ☐ Amendment

Environmental Determination(s): ☐ Categorical Exclusion☐ Negative Determination ☐ Positive Determination ☐ Deferral

Initial Environmental Examination


Expiration Date:Additional Analyses/Reporting Required:Climate Risks Rating for Risks Identified: Low _____ Moderate _____ High

_____

SUMMARY OF FINDINGSPURPOSE AND SCOPE OF THE INITIAL ENVIRONMENTAL EXAMINATION [INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a brief statement that this is an Initial Environmental Examination (IEE) for (activity title) operating in the (region) of (country) from (start to end date). If the purpose is to amend a previous IEE to add scope and new activities, briefly state this and what else is changing (funding amount, life of award, geographic scope).]

ACTIVITY SUMMARY[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a brief summary of the activity. Concisely describe how this IEE relates to any other RCEs/IEEs/EAs that cover this activity area for the mission or operating unit.]

ENVIRONMENTAL DETERMINATIONS [INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a summary of the environmental determinations applicable to the specific activities.]

Upon approval of this document, the determinations become affirmed, per Agency regulations (22 CFR 216).

IMPLEMENTATIONIn accordance with 22 CFR 216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Sections 3, 4, and 5 of the IEE and any BEO Specified Conditions of Approval.


USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

ACTIVITY NAME:

Approval: __________________________________________________Mission Director

_____________Date

Clearance: __________________________________________________Food for Peace Officer (FFPO)*

______________Date

Clearance: __________________________________________________Mission Environmental Officer (MEO)

______________Date

Clearance: __________________________________________________Agreement Officer’s Representative (AOR)

______________Date

Clearance: __________________________________________________Agreement Officer (AO)

______________Date

Clearance: __________________________________________________Regional Environmental Advisor (REA)*

______________Date

Clearance: __________________________________________________Kyle Rearick, Climate Integration Lead (CIL)

______________Date

Concurrence:

__________________________________________________Erika J. Clesceri, DCHA Bureau Environmental Officer (BEO)

______________Date

*Clearance recommended, but optional.


THRESHOLD DECISION MEMOBEO SPECIFIED CONDITIONS OF APPROVAL[THIS SECTION IS TO BE COMPLETED BY USAID UPON APPROVAL OF THIS ACTIVITY-LEVEL IEE.]

[BEOS MAY PROVIDE SPECIFIC CONDITIONS TIED TO USAID APPROVALS. IN CASES WHERE NO ADDITIONAL CONDITIONS OF APPROVAL ARE REQUIRED, THIS SECTION RECEIVES A “N/A”. THIS APPROACH IS USED TO PROVIDE DIRECT AND SPECIFIC CONDITIONS TO THE IPS AND MAY BE PRESENTED IN THREE PARTS: 1) ISSUE; 2) DISCUSSION; 3) CONDITION.]

[Remaining page is intentionally left blank.]


1.0 ACTIVITY DESCRIPTION1.1 PURPOSE AND SCOPE OF IEE[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This section explains the purpose and scope of the IEE. Standard language is provided below to be augmented with activity specifics. If the purpose is to amend a previous IEE to add scope and new activities, briefly state this and what else is changing (funding amount, life of award, geographic scope). Briefly describe how this IEE relates to any other RCEs/IEEs/EAs that cover this activity area for the operating unit.]

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID intervention described herein and recommend determinations and, as appropriate, conditions, for these activities. Upon approval, these determinations become affirmed, per 22 CFR 216 and specified conditions become mandatory obligations of implementation. This IEE also documents the results of the activity’sClimate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

This IEE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation. Potential environmental impacts are addressed through formal environmental mitigation and monitoring plans (EMMPs) attached and/or Environmental Assessments (EAs), if needed.

1.2 ACTIVITY OVERVIEW [INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): In this section provide a brief overview of the activity.]

1.3 ACTIVITY DESCRIPTION[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Describe the activity interventions. This information can be presented in table form, see below. Clearly describe the interventions in detail sufficient to determine whether (1) they belong to classes of actions eligible for Categorical Exclusion and (2) whether direct or indirect impacts are reasonably foreseeable. For guidance in preparing your 22 CFR 216 documentation, please visit http://www.usaidgems.org/Assistant/gettingStarted.htm.]

TABLE 1: DEFINED INTERVENTIONS[Intervention 1 — Title][Intervention 2 — Title][Intervention 3 — Title][Intervention 4 — Title][Intervention 5 — Title]


[Intervention 6 — Title][Intervention 7 — Title][Add rows as needed]


2.0 BASELINE ENVIRONMENTAL INFORMATION[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Include information pertinent to making informed environmental determinations and improving mitigation and monitoring of activities.]

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL)[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This section is to be tailored and include baseline environmental condition information appropriate to the activity context and scale. The information obtained in this section should serve as an environmental baseline for future environmental monitoring and evaluation and may include information on public health and safety, atmospheric and air quality, water quality, indigenous peoples, etc.]

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS (E.G. WHO), ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): In this section, summarize partner country environmental, health, and safety laws and regulations, as well as those pertaining to land tenure, relevant to the proposed activities. Discuss applicable permit requirements, policies, and regulations, including whether partner country Environmental Impact Assessment requirements apply.]

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS APPROPRIATE)[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): If government-to-government agreements are planned, discuss the state of the entities’ legal enforcement authority, institutional arrangements and capacity building, compliance monitoring, enforcement response, compliance assistance and information management, economic and other incentive-based instruments, indicators to evaluate program success and programmatic priority-setting, public participation, etc. As applicable, also discuss the capacity of local governmental and non-governmental organizations to implement applicable permit requirements, policies, laws and regulations. If there have been consultations with the partner government on the environmental capacity analysis, they should be described here.]

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK1

[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): In this section, analyze and document all potential adverse environmental and social impacts of activity interventions, such as water quality impairment, habitat alteration, resource depletion, health, safety, contributions to climate change, increased vulnerability to climate change impacts, etc. With regards to climate change, consider how your

11 Includes analysis of environmental and social40

USAID/DCHA FFP FY18 RFA IEE

activity might contribute to greenhouse gas emissions (e.g., through diesel generators) and how climate impacts may exacerbate the environmental impacts of your activity (e.g., by reducing water flows). How climate risks may impact the success of your activity is considered separately in section 4.2. The information from this section will support analysis sufficient to identify the appropriate mitigation measures and monitoring indicators necessary to avoid or sufficiently reduce impacts of the activity.]


[INTERVENTION 1TITLE][INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a narrative detailing potential adverse environmental and social impacts for the intervention and summarize results in the table.]

TABLE 2A: POTENTIAL IMPACTS – [INTERVENTION 1 TITLE]

[Intervention Title] Potential environmental and social impacts[Description of Intervention]

[Add rows as needed]

[INTERVENTION 2 TITLE][INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a narrative detailing potential adverse environmental and social impacts for the intervention and summarize results in the table.]

TABLE 2B: POTENTIAL IMPACTS – [INTERVENTION 2 TITLE][Intervention Title] Potential environmental and social impacts[Description of Intervention]


[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Add narratives and summary tables as needed for additional activity interventions.]

4.0 ENVIRONMENTAL DETERMINATIONS 4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS [INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a narrative summary of the recommended determinations based on the environmental analysis conducted.]

The following table summarizes the recommended determinations based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22 CFR 216.

[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): For Table 3, add your intervention titles in the table below and place an X in the appropriate column for each title.]


TABLE 3: ENVIRONMENTAL DETERMINATIONS

Interventions

Categorical Exclusion Citation (if applicable)

Negative Determination

Positive Determination Deferral

[Intervention 1 Title][Intervention 2 Title][Intervention 3 Title][Intervention 4 Title][Add rows as needed]

4.2 CLIMATE RISK MANAGEMENT [INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): In accordance with Agency policy, include a brief narrative of the risk assessment methodology and the Climate Risk Management Summary Table (table below or table from Climate Risk Screening and Management Tool). Refer to ADS 201mal “Climate Risk Management for USAID Projects and Activities.”]

TABLE 4: CLIMATE RISK MANAGEMENT SUMMARY TABLEDefined or Anticipated Program Interventions

Timeframe Geography Climate Risks

List key risks related to the program interventions identified through either the strategy- or project-level climate risk assessment.

Risk Rating

Low/ Moderate/ High





[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Add rows as needed.]


5.0 MITIGATION MEASURES[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a narrative here detailing required mitigation measures for reducing the undesirable impacts of the activities on the environment.]

The mitigation measures presented in this section constitute the minimum required based on available information at the time of this IEE and the environmental analysis in Section 4.

[INTERVENTION 1 TITLE]

TABLE 5A: SUMMARY OF MITIGATION MEASURES FOR [INTERVENTION 1 TITLE][Intervention Title] Mitigation Measures[Description of Intervention]


[INTERVENTION 2 TITLE]

TABLE 5B: SUMMARY OF MITIGATION MEASURES FOR [INTERVENTION 2 TITLE][Intervention Title] Mitigation Measures[Description of Intervention]

[Add rows as needed][INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Add summary tables as needed for additional activity interventions.]

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION The determinations recommended in this document apply only to interventions described herein. Other activities that may arise must be documented in either a separate IEE, an IEE amendment if the activities are within the same activity, or other type of environmental compliance document and shall be subject to an environmental review.

Other than activities determined to have a Positive Threshold Decision, it is confirmed that the activities described herein do not involve actions normally having a significant effect on the environment, including those described in 22CFR216.2(d).


It is confirmed that the activities described herein do not involve any actions listed below. Any of the following actions would require additional environmental analyses and environmental determinations:

[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Remove any bullets below covered by this IEE.]

o Support project preparation, project feasibility studies, or engineering design for activities listed in §216.2(d)(1);

o Affect endangered and threatened species or their critical habitats per §216.5, FAA 118, FAA 119;

o Provide support to extractive industries (e.g. mining and quarrying) per FAA 117;

o Promote timber harvesting per FAA 117 and 118;o Lead to new construction, reconstruction, rehabilitation, or renovation work

per §216.2(b)(1);o Support agro-processing or industrial enterprises per §216.1(b)(4);o Provide support for regulatory permitting per §216.1(b)(2);o Lead to privatization of industrial facilities or infrastructure with heavily

polluted property per §216.1(b)(4);o Procure or use genetically engineered organisms per §216.1(b)(1); and/oro Assist the procurement (including payment in kind, donations, guarantees of

credit) or use (including handling, transport, fuel for transport, storage, mixing, loading, application, clean-up of spray equipment, and disposal) of pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials. Pesticides cover all insecticides, fungicides, rodenticides, etc. covered under the Federal Insecticide, Fungicide, and Rodenticide Act per §216.2(e) and §216.3(b).

7.0 REVISIONSPer 22 CFR 216.3(a)(9), when ongoing programs are revised to incorporate a change in scope or nature, a determination will be made as to whether such change may have an environmental impact not previously assessed. If so, this IEE will be amended to cover the changes. Per ADS 204, it is the responsibility of the USAID AOR and awardees to keep the MEO/REA and BEO informed of any new information or changes in the activity that might require revision of this environmental analysis and environmental determination.

ATTACHMENTS:

1. ENVIRONMENTAL MITIGATION AND MONITORING PLAN

2. REFERENCE DOCUMENTS


ANNEX 2: TEMPLATE FOR ENVIRONMENTAL MITIGATION AND MONITORING PLANS [INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Awardees may organize their EMMPs by sector, if appropriate. In any case, all interventions with the potential for environmental effect from the activity’s Logical Framework must be covered in the EMMP.]

Interventions

Identified Environmental Aspects or Impacts

Mitigation Measure(s)

Monitoring Indicator(s)

Monitoring and Reporting Frequency/ Methods

Responsible Parties

[Intervention 1 Title]








ANNEX 3: TEMPLATE FOR ENVIRONMENTAL STATUS REPORTS

ENVIRONMENTAL STATUS REPORT (ESR)ACTIVITY DATA

Activity Name:Geographic Location(s) (Country/Region):Implementation Start/End Date:Award Number:Implementing Partner(s):Link of Related IEE: Life of Award (LOA) $:


DCHA Office:Lead BEO Bureau:Prepared by:Date Prepared:

ENVIRONMENTAL COMPLIANCE REVIEW DATA

PREP Year:Environmental Action Recommended:

Categorical Exclusion:Positive Determination: Negative Determination:Deferral:


PURPOSE AND SCOPEEnvironmental Status Reports (ESRs1) are required for USAID-funded activities when the 22 CFR 216 documentation governing the activity imposes conditions on at least one of the activity’s interventions. ESRs ensure that the ADS 204 requirements for reporting on environmental compliance are met.

The ESR meets both purposes of reporting and budget planning. ESRs report on status of mitigation and monitoring efforts in accordance with IEE requirements over the preceding activity implementation year. The also ESR describes environmental compliance resource needs over the course of the upcoming year (e.g., staffing, assessments, training, etc).

The ESR is submitted by the Implementing Partner at least three (3) months prior to the annual Pipeline and Resource Estimate Proposal (PREP), The PREP describes an awardee's food security resource needs and activities over the course of the upcoming year.

11 The ESR is similar to the Environmental Mitigation and Monitoring Report (EMMR) used elsewhere in USAID. However, the ESR meets both purposes of reporting and budget planning for environmental compliance.


USAID APPROVAL OF ENVIRONMENTAL STATUS REPORT

ACTIVITY NAME:

Clearance:______________________________________Mission Environmental Officer (MEO)

___________________Date

Clearance:______________________________________Food For Peace Officer (FFPO)*

___________________Date

Clearance:______________________________________Regional Environmental Officer (REO)*

___________________Date

Clearance:______________________________________Agreement Officer’s Representative (AOR)

___________________Date

Concurrence:

______________________________________Erika J. Clesceri, DCHA Bureau Environmental Officer (BEO)

___________________Date

DISTRIBUTION: DCHA Climate Integration Lead (CIL); Regional Bureau Environmental Officer (BEO)

*Clearance recommended, but optional.


1.0 INTRODUCTION TO THE ENVIRONMENTAL STATUS REPORT[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a brief synopsis of progress towards achieving environmental compliance and climate risk management objectives as detailed in the RFA IEE, Activity-level IEE and EMMP.

Awardees whose programs are making only limited progress towards achieving environmental compliance and climate risk management objectives should provide an explanation. Describe the extenuating circumstances outside of the control of the award that are impeding progress, and top-line approaches to address these obstacles in the upcoming years.]

2.0 STAFFING AND BUDGET FOR UPCOMING IMPLEMENTATION YEAR[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This section must include responses to Topics 1-4.]

A. STAFFING AND EXPERTISE:[Topic 1: Describe staffing plan for environmental safeguards for the next year. Include responsibilities, level of effort, and authority of staff. A full-time staff with relevant expertise is required for monitoring and reporting on USAID environmental compliance in a timely and professional manner. For guidance, refer to the USAID toolkit describing methods for budgeting.] [Topic 2: Please describe any environmental assessments (e.g., roads, irrigation), trainings or workshops that will be carried out in the upcoming implementation year (e.g. EA, PERSUAP, FMP, climate risk or vulnerability assessments, community resource mapping exercise, staff training on EMMP monitoring.)]

B. RESOURCES NEEDS FOR ENVIRONMENTAL COMPLIANCE:[Topic 3: Provide a description of the upcoming year’s resource needs for the materials and services for environmental requirements. Illustrative needs are described in Box 2 “Common Materials and Services Needed for Environmental Requirements in FFP Projects” on Page 13 of the USAID toolkit on how to develop and review an environmental compliance budget.]

[Topic 4: Demonstrate that the activity’s budget for environmental compliance is described in the PREP budget and narrative. Where individual budget line items for environmental compliance actions do not exist, then these actions must be described in the budget narrative. This budget indicating resources needs may be


reviewed as part of the ESR clearance, and lack of clarity here will cause delays in approval.]


3.0 PROGRESS TOWARDS ENVIRONMENTAL COMPLIANCE [INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This section must include responses for Topics 5-11.]

A. PREVIOUS BEO CONDITIONS:[Topic 5: Describe compliance with USAID BEO Conditions from any and all BEO Decision Memos. A specific discussion must be included for each Condition. Discuss challenges or opportunities identified]

B. EMMP REPORTING:[Topic 6: Provide a brief narrative on progress implementing the EMMP. Include description of the EMMP environmental monitoring systems. Include staff or beneficiary trainings conducted, photos of mitigation measures and activities, etc.]

C. INTEGRATION INTO PERFORMANCE M&E SYSTEMS:[Topic 7: Indicate how the awardee has ensured sufficient inclusion of environmental aspects (as in the EMMP) into the M&E Plan, as described in FFP's Policy and Guidance for Monitoring, Evaluation, and Reporting for Development Food Security Activities (Section 2.4 on EMMP, p. 36).]

[Topic 8: Briefly describe any USAID climate risk indicator or other environmental performance indicator. Full details of the results of the indicators are primarily discussed in the Annual Results Reports (ARRs), and need not be described fully.]

D. CLIMATE RISKS AND OTHER ENVIRONMENTAL LIMITING FACTORS:[Topic 9: Provide a description of how the awardee has integrated climate risks and geohazards into activity design and implementation. If applicable, awardees must specifically discuss how Climate Risk Management Screening was completed for all activity elements, per the Climate Risk Management for USAID Projects and Activities A Mandatory Reference for ADS Chapter 201 and guidance found in the RFA IEE. In the description include how findings from Climate Risk Management Screening, particularly all risks classified as ‘moderate’ and ‘high,’ have and will be integrated into activity implementation. Also include a discussion of plans to reduce risk from other environmental limiting factors, such as geohazards, as in 22 CFR 216.1(b)(4).]

E. FUMIGATION PEA:[Topic 10: Provide a description of how awardee is meeting the USAID Programmatic Environmental Assessment (PEA) for Phosphine Fumigation of Stored Agricultural Commodity, by attaching the most recent Fumigation Management Plan


(FMP). If no FMP has been completed, provide justification. For activities that are not managing Title II or locally-procured commodity, then disregard.]

F. LESSONS LEARNED AND INNOVATION:[Topic 11: Discuss any other lessons learned and/or innovation regarding the implementation of systems for climate and environmental resilience and compliance. The awardee is asked to share with USAID any examples to institutionalize environmental safeguards as a cross cutting theme into the awardee’s monitoring systems (e.g. field-based environmental monitoring systems, community-level social and behavioral change tools/strategies, community incentive awards, etc).]

4.0 EMMP REPORTING TABLE[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This table should align with the most recent version of the activity’s Logical Framework. Please indicate where changes have been made. Any substantial changes to interventions will require an IEE and EMMP Amendment and USAID’s approval. ]

Interventions

EMMP Mitigation Measures

(Indicate any additions or deletions)

EMMP Indicators

(Indicate any additions or deletions)

Results Remarks and Description of Necessary Corrective Actions


5.0 ATTACHMENTS[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Include relevant attachments, such as water quality test results, Fumigation Management Plans (FMPs), etc.]



ANNEX 4: GUIDANCE FOR CLIMATE RISK MANAGEMENT SCREENINGIntegrating climate risks into project and activity planning helps limit the impacts of climate on implementation. USAID conducts Climate Risks Management (CRM) screening to assess and address climate risks and opportunities in strategies, projects, and activities. This screening is included in the initial environmental examination (IEE), and it will be included in the DCHA Bureau Environmental Officer (BEO) technical review of the IEE. Below is a set of guidance notes and resources to complete the CRM screening.Requirements: The requirements and basic guidance for completing the climate risk management (CRM) screening at the project and activity level is available in Mandatory Reference for ADS Chapter 201: CRM for USAID Projects and Activities (ADS Guidance). The guidance specific to Activity-Level screening should be followed. This includes development of an Activity-Level Climate Risk Management Summary Table (CRM Table). The table structure showing all columns we require can be seen in Table 1 below.

TABLE 1. CLIMATE RISK MANAGEMENT SUMMARY TABLEDefined or Anticipated Activity Interventions

Timeframe

Geography

Climate Risks

List key risks related to the activity interventions identified through either the strategy- or project-level climate risk assessment.

Risk Rating

Low/Moderate/ High





Table + Narrative: In addition to the CRM Table, the ADS Guidance requires a “summary of the approach to activity-level CRM and major results”. This should briefly clarify how risks were identified and assessed, and also include critical resources referenced. If there are opportunities to reduce greenhouse gas (GHG) emissions associated with implementing the activity, describe them in the narrative.


CRM Table References: USAID has developed Climate Risk Screening and Management Tools to support this process and provide step-by-step guidance on completing the CRM Table. In particular, please use the Climate Risk Screening and Management Tool for Activity Design (CRM Tool) and the accompanying Matrix Template. While Table 1 (above) shows all columns we require, you may also choose to complete and submit additional columns found in the Matrix Template.

Within the CRM Tool, use the sector-specific annexes, which begin on page 14. In particular, see annexes on “Education, Social Services, and Marginalized Populations”, “Agriculture”, and “Infrastructure, Construction, and Energy”. USAID also developed a technical report entitled “Working with Marginalized Populations: An Annex to the Climate-Resilient Development Framework”. Additional sector-specific environmental design and management information can be found in the USAID Sector Environmental Guidelines, many of which include specific sections covering climate change.

All Activities Screened: Initial screening and risk rating must be conducted and documented for all proposed activities. Section 1 (page 5) of the ADS Guidance outlines the only exceptions, (i.e., emergencies, staffing, research, monitoring). Aside from the excepted activities, all others (including Categorical Exclusion activities) must be screened for climate risks.

All Potential Impacts: The full range of potential climate impacts which might affect the activities must be considered during the climate risk screening. This should be based on reliable available resources and information. The USAID ClimateLinks website provides country and region-specific profiles on climate vulnerability, risk and/or adaptation. The World Bank Climate Change Knowledge Portal also offers country-specific information on historical climate, future climate projections, and climate change impacts and vulnerabilities. Local knowledge and expertise (including from facilities / operations personnel who have experience with local climate risks affecting the school/hospital) should inform the screening, when available and appropriate. The DCHA Climate Integration Lead can also be consulted to provide additional resources, if needed.

TABLE 2. CLIMATE RISK RATINGS


Climate Risk Rating: Based on the screening, all relevant climate risks for each proposed activity must be assigned a rating of Low, Moderate, or High. Table 2 below shows how the severity and probability of negative climate-related impacts interact to determine the climate risk rating. If a climate risk is rated as Low, then only the descriptions of the activity (including timeframe and geography), climate risk, and climate risk rating (columns 1-5) are necessary to include in the CRM Table (Table 1 above). For each climate risk that is rated as Moderate or High, the implementing partner should also describe how the risks will be addressed as well as the opportunities to strengthen climate resilience (columns 6-8 in Table 1).

All interventions related to construction should be categorized as High Risk, and must be assessed and approved by Engineer of Record. The Engineer of Record is an appropriately qualified engineer or firm under contract or subcontract for the purpose of completing the engineering design. If the engineering design has not yet been developed, the DCHA Climate Integration Lead can approve an initial CRM Screening. The Engineer of Record must still ultimately review the initial CRM Screening and revise as necessary. The Engineer of Record must submit the revised, final CRM Screening table and narrative along with a signed document confirming his or her approval.

Example Climate Risk Management Measures: For climate risks rated as Moderate or High, the following illustrative risk management measures are examples of what can be considered when determining and documenting how to address the climate risks (6th column of Table 1).

Climate RisksConstruction Management Measures

-Construction workers may face increased risk of heat exhaustion or impacts of climate-related extreme events (e.g., heavy rain storms, flooding, dust storms or wildfires) -Extreme climate-related events (e.g., storms, wildfires, extreme heat and flooding), landslides, erosion, as well as sea level rise and associated storm surges can all affect the longevity of buildings and infrastructure. These impacts can be worsened or mitigated based on construction design and siting / location.

-The impacts above can also threaten routes and transportation systems necessary to access and utilize constructed buildings.

-Require that construction crews receive proper hydration and are not exposed to dangerously high heat levels, in accordance with local and national health and safety requirements.

-Ensure emergency plans are in place (and well communicated to crews) to respond to climate-related extreme events. -Use local knowledge and best practices to integrate design measures to address specific potential climate stressors (e.g., use more resilient materials or construction methods, design for future upgrades/repairs, or elevate to accommodate rising sea levels)

-Consider alternative locations if proposed site faces higher climate


risks (e.g., floods, wildfires, high winds, storms, or other site-specific threats) than other potential, appropriate locations

-Consider locations with multiple access routes, particularly if at least one alternative is protected against relevant climate risks (e.g., paved to protect against wash-out during flooding or routed to avoid low-lying areas possibly affected by storm surges)

Climate RisksCommodities Management Measures

-Extreme climate-related events (e.g., storms, wildfires, extreme heat, droughts, and flooding), landslides, erosion, as well as sea level rise and associated storm surges can all directly affect selected sites in which commodities will be delivered, used and maintained. -Changing rainfall patterns, higher temperatures, or climate-related extreme events may affect transportation routes for delivery or access of commodities -Changing rainfall patterns or drought conditions could affect availability of water necessary for use or maintenance of commodities

-Consider alternative locations/buildings/rooms if proposed site faces higher climate risks (e.g., floods, wildfires, high winds, storms, or other site-specific threats) than other potential, appropriate locations -Determine whether additional protective measures can be added to the commodity or structure in which it is housed to increase resilience to climate risks -Develop and/or make use of existing weather/climate information and early warning systems to improve preparedness for and response to climate-related extreme events -Determine or develop back-up/alternative access routes for commodity delivery or for access to and use of commodities -Determine if alternative water sources are available and develop plans for accessing them if necessary
