USAID Environmental Guidelines Purpose and Overview YMEP Environmental Training Overview USAID Environmental Guidelines Purpose and Overview

Fate and Transport of Pollution in the Environment Sources Pathway Target

Exposure Scenario

Protecting Against Environmental Risk Risk = Hazard x Exposure hazard: A circumstance/event with potential to cause harm. A hazard itself presents no risk until something is exposed to it. exposure: A particular amount of time something comes in contact with a hazard or the number of times something comes in contact with a hazard. Hazard x Exposure = No Risk Hazard x Exposure = No Risk There really is no such thing as zero risk

ADS Chapter 204 Environmental Procedures 22 CFR 216 Regulations 22 CFR 216 codifies USAID’s procedures for assessing assessment of our programs Applies to every program, project, activity, and amendment supported with USAID funds Every USAID Officer Who Has a Role in USAID Funded Projects Every Partner Who Seeks USAID Funds Compliance with the procedures is mandatory ADS Chapter 204 Environmental Procedures This chapter provides policy directives and required procedures on how to apply Title 22 of the Code of Federal Regulations,

Categorical Exclusion Initial environmental examination Reg 216: The big picture Most activities are cleared with: system, Reg. 216 features a tiered review system to focus review effort where it is needed. Activities specified by the regulation as having minimal environmental impact Increasing risk/impact Categorical Exclusion Initial environmental examination A much shorter, simpler version of a full EIA study Reg 216 specifies that an IEE must reach 1 of 2 decisions: Full EIA Requires a professional team, 2+ person months Positive determination, (significant impacts likely, do full EIA) Negative determination, (no significant impacts, proceed with activity)

Exemptions from 216 Requirements Under Reg 216, EXEMPTIONS are ONLY. . . Exemptions require a formal determination by the Administrator or Assistant Administrator that includes consultation with CEQ regarding the environmental consequences of the proposed program, project or activity. International disaster assistance Other emergency situations Circumstances with “exceptional foreign policy sensitivities” “Exempt” activities often have significant adverse impacts. Good practice requires mitigating these impacts, where possible.

USAID Screening Categories: Categorical Exclusions A specific set of activities believed to have minimal environmental impacts have been identified for possible exclusion from the 216 Illustrative examples include: No categorical exclusions are possible when an activity involves pesticides Education, tech. assistance, training Documents or information transfers Analyses, studies, academic or research workshops and meetings Support to intermediate credit institutions where USAID does not review loans Nutrition, health, family planning activities except where infectious medical waste is generated Categorical exclusions exist AT THE DISCRETION of the BEO Support to intermediate credit institutions where USAID does not review or approve loans: Categorical Exclusions apply only to capitalize an intermediate credit institution (ICI) where USAID does not review and approve each loan. If a Categorical Exclusion is not appropriate, the IEE preparer should recommend a negative determination or a deferral. For the IEE, identify types of participating enterprises, and any guidelines the intermediate credit institution uses to screen loans. NO CATEGORICAL EXCLUSION WHEN AN ACTIVITY INLCUDES ASSISTANCE FOR THE PROCUREMENT OR USE OF PESTICIDES New Environmental Executive guidelines on Categorical Standards emphasize need for case by case review of CATEX applicabiility And certain other situations where USAID does not have direct knowledge or control

New Guidance Requires Affirmative Evaluation of CATEX Applicability Institutional Capacity Building Case Study Project Includes: Senior LT Advisor to Ministry of Mining on Best Practices Assist in c concession negotiations Supervise cadastre and legal reform work STTA on concessions and legal reform Training Ministry Staff

Basic Reg. 216 compliance documents The RCE is a simple document used when ALL activities are “low risk” Request for Categorical Exclusion Goals and purpose of project: list activities Justification for a Categorical Exclusion (must cite the appropriate section of Reg. 216.) Initial Environmental Examination Goals and purpose of project; list of activities Baseline information Evaluation of potential environmental impacts Recommended findings, mitigation & monitoring No activities may be implemented without APPROVED Reg. 216 environmental documentation What about a request for EXEMPTION? Outline: Statement of justification; approved by the Assistant Administrator Only for emergency circumstances or circumstances of exceptional foreign policy sensitivity 3 A “facesheet” accompanies both the IEE & the CatEx Request The IEE is USAID’s “preliminary assessment”

Environmental Screening YMEP Environmental Training Overview Environmental Screening

Recommended Determinations in the IEE For each activity addressed, the IEE makes one of 4 recommendations regarding its possible impacts: Recommendation Reg. 216 terminology Implications (if IEE is approved) No significant adverse environmental impacts NEGATIVE DETERMINATION Activity passes environmental review With specified mitigation and monitoring, no significant environmental impacts NEGATIVE DETERMINATION WITH CONDITIONS The activity passes environmental review on the condition that the specified mitigation and monitoring is implemented Significant adverse environmental impacts are possible POSITIVE DETERMINATION Do full EA or redesign activity Not enough information to evaluate impacts DEFERRAL You cannot implement the activity until the IEE is finalized USAID vocabulary Significant impacts: Defined in Regulation 216 as impacts that do significant harm to the environment. Threshold Decision: The recommendation or finding reached by the IEE RE: the proposed activities’ effects on the environment: Negative Determination: A decision that a proposed action or activity will have no significant adverse environmental impacts. Activities which have only beneficial impacts on the environment also receive a negative determination. Positive determination: A decision that a proposed action or activity will have ‘significant impacts.’ Projects which both benefit and harm the environment should receive a positive determination, because despite their benefits the potential damage to the environment requires mitigation. In both cases the IEE results in a positive determination and a comprehensive review is required. Deferred determination or deferral: A decision to postpone IEE completion until sub-project activities are identified.

Umbrella IEEs for “Umbrella” Projects G.1 Umbrella projects and USAID’s Environmental Procedures The basic procedures described in Chapters 1–4 of this manual assume that proposed activities are sufficiently well-defined that the screening process can be undertaken and, if necessary, an IEE can be prepared. However, proposals often include activities that are not fully defined at the time the proposal is submitted. “Umbrella projects” are a common example of this situation. In an umbrella project, a number of small-scale activities are funded through subgrants under a larger project. Umbrella projects are commonly used to implement community-driven development schemes. They provide a mechanism to fund community proposals for small-scale activities. They may also be used to fund micro and small enterprise subprojects. Typically, a USAID partner organization receives overall funding for the umbrella project. The partner then functions as a subsidiary grantmaker, using a portion of the overall funding to award small-scale grants. Under certain circumstances, however, USAID itself assumes the role of managing the subproject proposal and grant-making process.

CLP Program is an Example of an Umbrella IEE

Beyond the IEE YMEP Environmental Training Overview Environmental Assessments/ Environmental Impact Statements PERSUAPS Programmatic Environmental Assessments

1 2 3 4 5 EA Requirements The full EA study includes: A formal scoping process precedes the study to ID issues to be addressed Analysis of environmental impacts is much more detailed Alternatives* must be formally defined. The impacts of each alternative must be identified & evaluated, and the results compared. Public participation is usually required. A professional EIA team is usually required. The full EA study includes: 2 3 4 *includes the project as proposed, the no-action alternative at least one other real alternative 5

Programmatic Environmental Assessment Programmatic Approaches An Office of USAID may undertake an environmental assessment within a sector (agriculture, road construction, etc.) or a larger program to help define and mitigate potential environmental concerns in the design of a program or strategy. Such an overall assessment is known as a Programmatic Environmental Assessment (PEA) and can serve as a general assessment of a sector or provide the basis for future environmental reviews, at either project or sub-project level. Section 216.6(d) of Reg. 216: (d) PROGRAM ASSESSMENT: Program Assessments may be appropriate in order to: -- assess the environmental effects of a number of individual actions and their cumulative environmental impact in a given country or geographic area, or -- the environmental impacts that are generic or common to a class of agency actions, or -- other activities which are not country-specific.

Pesticide Evaluation Report & Safer Use Action Plan (PERSUAP) Originated in the Africa Bureau, but increasingly being adopted elsewhere, the PERSUAP constitutes the pesticide analysis of the IEE*, or takes its place. The PERSUAP can be self-standing, be attached to the IEE, or submitted later to resolve a pesticide use deferral PERSUAP has two major parts: * or as a response to a Negative Determination with Condition to prepare a PERSUAP ** e.g., High Value Crop Codes of Conduct, EurepGAP, ISO 14001, Sanitary and Phytosanitary standards While preparing the PERSUAP, if you find that the pesticide use may present a significant hazard to human health or the environment, you can look at alternative pesticides that might be less harmful. As described previously, preparing the IEE is an iterative process: for the PERSUAP, talk to people in the field, talk to buyers, find out what pesticides are being recommended and used and which are preferrable. Substitute less toxic ones and analyze those in the PERSUAP. Don’t forget that for USAID, biological pesticides are treated the same way as chemical controls and their use must be analyzed in a PERSUAP. 1 2 Pesticide Evaluation Report & Safer Use Action Plan Response to the Pesticide Procedures requirements Identifies actions and actors for mitigation & monitoring, including compliance with host country & private** procedures

Monitoring Environmental Compliance YMEP Environmental Training Overview Monitoring Environmental Compliance

USAID Must Monitor IP Performance with Environmental Requirements Implementing Partners must provide USAID with verifiable monitoring information about environmental compliance.

Definition: Environmental monitoring is BOTH. . . Environmental monitoring is a necessary complement to mitigation. It should be a normal part of monitoring project results.  1. Systematic measurement of key environmental indicators over time (is the mitigation measure sufficient, effective?)  Systematic verification of mitigation (are the prescribed measures being implemented?)

Environmental Monitoring and Mitigation Plans Mitigation and monitoring is set out in Environmental Mitigation and Monitoring Plans (EMMPs)