US Agency for International Development (USAID) / India

Initial Environmental Examination (IEE)

HIV Services for Key Populations Affected by HIV/AIDS

Program/Project/Activity Data:Activity/Project Title: HIV Services for Key Populations Affected by HIV/AIDS

Solicitation #: TBD

Contract /Award Number (if known): Award No TBDGeographic Location: IndiaOriginating Bureau/Office: USAID/India, Health OfficeSupplemental IEE: ☐ Yes ☒ NoAmendment: ☐ Yes ☒ NoProgrammatic IEE: ☐ Yes ☒ No

DCN and date of Original document: N.ADCN and ECD link (s) of Amendment (s): N.AAmendment No: N.A

Funding Amount: $20 Million Life of Project Amount: $20 Million

Implementation Start/End: FY 2018/ FY 2022Prepared By: Sara Heydari Date Prepared: December 26, 2017Expiration Date (if any): N.A. Reporting due dates (if any): N.AEnvironmental Media and /or Human Health Potentially Impacted (check all that apply)None ☒ Air ☐ Water ☐ Land ☐ Biodiversity ☐ Human Health ☐ Other ☐Recommended Threshold Determination: ☒ Negative Determination ☒With Conditions☐Categorical Exclusion☐ Positive Determination

☐ Deferral☐ Exemption☐ USG Domestic NEPA action

Climate Change☐ GCC/Adaptation ☐ GCC/Mitigation ☐ X Climate Change Vulnerability Analysis (included)

Adaptation/Mitigation Measures: Not Applicable

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SUMMARY OF FINDINGS

Pursuant to 22 CFR 216.2(a), an environmental analysis/evaluation and climate risk screening are required for new projects, programs or activities authorized by USAID. This Initial Environmental Examination (IEE) evaluates activities to be implemented by PEPFAR funds under the USAID/India’s ‘HIV Services for key Populations Affected by HIV/AIDS’ activity over a period of 5 years.

Recommended Action:

(i) Categorical Exclusion: Pursuant to 22 CFR 216.2(c)(3), the USAID/India’s Health Office, the "originator" of the subject activities, has determined that the program activities, representing 80% of the total project’s LOP funding level, consist of types of interventions entirely within the categories listed in 216.2(c)(2) and are therefore recommended to be categorically excluded by falling under the following classes of actions:

The action does not have an effect on the natural or physical environment {22 CFR 216.2(c)(1)(i)};

Education, technical assistance, training programs, development of training material, workshops and meetings except to the extent such programs include activities directly affecting the environment {22 CFR 216.2(c)(2)(i)};

Controlled experimentation exclusively for the purpose of research and field evaluation which are confined to small areas and carefully monitored {22 CFR 216.2(c)(2)(ii)};;

Analyses, studies, academic or research workshops and meetings {22 CFR 216.2(c)(2)(iii)}; Projects in which A.I.D. is a minor donor to a multidonor project and there is no potential

significant effects upon the environment of the United States, areas outside any nation's jurisdiction or endangered or threatened species or their critical habitat{22 CFR 216.2(c)(2)(iv)};

Document and information transfer {22 CFR 216.2( c)(v)}. Studies, projects or programs intended to develop the capability of reciepient countries and their

institutions to engage in development planning, except to the extent designed to result in activities directly affecting the environment {22 CFR.2(c)(2)(xiv)}.

(ii) Negative Determination with Conditions (NDC): This is recommended for results representing 20% of the total project’s LOP funding level, involving expanded access to comprehensive HIV testing, treatment and care services that may have the potential impact on the natural or physical environment (refer Section 2 of Table 1). The implementer will assess the proposed concept note (cooperative agreement) for potential environmental risks using the Environmental Review and Assessment Checklist (ER Checklist) attached as Annexure 1. For those results that are categorized as NDC, the implementer(s) will develop an Environmental Mitigation and Monitoring Plans (EMMP), which is in line with the Government of India’s Ministry of Environment, Forest and Climate Change Bio-Medical Waste Guideline, 2016 and WHO guidance on Safe management of wastes from health-care activities, 2nd Edition, 2014. The AOR and the Mission Environmental Officer (MEO) will review and approve the ER Checklist and EMMP. If, after review of the EMMPs, a potential

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significant adverse environmental and/or social effects are confirmed, a Scoping Statement (SS) and Environmental Assessment (EA) shall be done by the implementer prior to start of the activity in accordance with 22 CFR 216. The EA process shall include the following steps: 1) The concept note shall be reviewed and approved by Asia Bureau Environmental Officer (BEO/Asia,) 2) public consultation with potentially affected people and key relevant stakeholders, 3) Scoping Statement with refined Project Description for EA shall be reviewed and approved by the BEO/Asia, 4) draft EA report is subject to public consultation with potentially affected people and key relevant stakeholders, 5) EA report is reviewed and approved by the BEO/Asia and duly national environmental authoriy.

(iii) Climate Risk Screening : The initial screening of the project against climate change effects indicate that the activities do not pose social or environmental risks that need to be further analyzed. None of the proposed project activities will be exposed to climate hazards like cyclones, droughts, floods and storm surges. There are no demographic and socio-economic aspects of the project that increase the vulnerability of the project to climate change. Based on the information none of the proposed project activities will effect climate change and eco-systems and cause GHG emissions. However, the link between HIV and AIDS and Climate Change should be understood and managed by the Implementing partner while undertaking the interventions.

HIV has become an important health challenge in most countries with the pandemic having profound socioeconomic ramifications at the household, community, national, regional and global levels with outstretched needs for management and care.

The epidemic has raised the disease burden in developing countries considering the resurge of diseases that were previously under control. It has taken advantage of populations with compromised immune systems with notable increase of tuberculosis and other respiratory diseases. The management and care of HIV and AIDS patients has relied on improved nutrition which is being threatened by constant food insecurity. Disasters linked to climatic changes like floods and droughts have ravaged populations causing great humanitarian suffering without discriminating People Living with HIV (PLHIV).

Climate change may have no direct link with HIV modes of transmission, but could have a direct link in the management and care of PLHIV. Good nutrition is a major component of HIV and AIDS management and care, a factor of food security which has a direct relationship with climate. Adherence needs of people living with HIV and AIDS to treament is usually affected during droughts and floods which are manifestations of climatic changes. Climate change impacts in any sector may therefore ultimately have a direct or indirect bearing to the health of affected communities. This makes it even more important for the stakeholders in HIV interventions to be at the forefront in understanding the climate change and variability impacts in order to better deal with real and potential challenges in HIV management and care.

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Tasks/Defined or Illustrative Interventions

Climate RisksList key risks related to the defined/illustrative interventions identified in the screening and additional assessment.

Risk RatingLow/Moderate/High

How Risks are AddressedDescribe how risks have been addressed in activity design and/or additional steps that will be taken in implementation. If you chose to accept the risk, briefly explain why.

Opportunities to Strengthen Climate ResilienceDescribe any opportunities to achieve multiple development objectives by integrating climate resilience or mitigation measures.

Task 1: Increased accessibility and availability of quantity HIV clinical and social services.

Climate hazards can interrupt or delay access to health care.

Low Accepted; sustaining improvements in the existing national HIV response, demonstrating and assessing innovative and cost-effective models to increase access and availability of quality HIV healthcare.

Using IEE as a vehicle to raise awareness of potential linkages.

Reduced food security decreases overall nutrition and health of population, which may be of concern to patients with preexisting conditions, such as HIV.

Low Accepted. Using IEE as a vehicle to raise awareness of potential linkages.

Task 2: Increased and sustained demand for quality HIV services

None. N/A N/A N/A

Task 3: Strengthened

None. N/A N/A N/A

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systems and enabling environmentTask 4: Enhanced learning and cost effectiveness

None. N/A N/A N/A

1. BACKGROUND AND ACTIVITY DESCRIPTION

1.1 Purpose and Scope of the IEE

The purpose of this IEE, in accordance with 22CFR216, is to provide the first review of the reasonably foreseeable effects on the environment, as well as recommended Threshold Decisions, under the HIV Services for Key Populations Affected by HIV/AIDS activity. This IEE provides a brief statement of the factual basis for a Threshold Decision as to whether an Environmental Assessment is required for this new activity.

The purpose of the project is to accelerate Government of India (GOI)’s HIV response through rapid demonstrations and assessments of efficient and effective models of HIV services through Technical Assistance (TA). USAID/India will contribute to the national AIDS control response, through identifying, developing, and strengthening clinical, organizational and systems capacity to scale up innovative HIV/AIDS prevention, testing and treatment interventions for (Key Populations) KP, their partners, spouses and children, in order for India to achieve sustainable epidemic control by 2030. This project will contribute to improving health outcomes by improving access and availability of HIV and social services; and by increasing sustainable demand from KPs, partners, spouses and children. This project will also strengthen GOI systems by improving data driven planning and governance of the National AIDS Control Organization (NACO), and by addressing structural barriers such as stigma and discrimination. An integral part of this project is to enhance learning all along its implementation across all outcomes, and foster adaptive, innovative decision making among NACO at all levels-National, States and Districts to ensure the GOI’s capacity to scale up evidence-based new models of HIV delivery of health services. USAID will support the new HIV/AIDS project through PEPFAR funds.

1.2 Background

India is at a critical junction of controlling its HIV/AIDS epidemic. Strengthening programs, based on understanding the epidemiological data and the epidemic drivers and the latest advances in prevention and treatment, is critical for India to stay ahead of the epidemic to achieve an AIDS-free generation by 2030.

While new HIV infections reduced at a high rate by an overall 66 percent in 2000-2015, the annual rate of decline was slow, especially since 2011. In some states in the northern and central part of the country, where transmission of the virus is driven by a combination of injecting drug use and sexual transmission, the new infections are rising (Gujarat, Uttar Pradesh and Punjab).

India continues to face a concentrated epidemic, driven by KPs. While the national prevalence among adults (15-49 years) has decreased to 0.26%, KPs remain at increased risk of HIV infection. According

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to national estimates, 6.25% of people who inject drugs (PWID), 3.14% of transgender/Hijra (TG/H), 2.69% of men having sex with men (MSM) and 1.56% of female sex workers (FSW) live with HIV.

1.3 Description of Activities

The overall goal of the program is to accelerate the GOI’s National HIV response to reach sustainable HIV epidemic control through rapid demonstration and assessment of models of HIV service delivery for key populations, their partners, spouses and children.

The program will support four interlinked strategies to:

(1) Increase access and availability of HIV and social services by demonstrating new models reaching the hard-to-reach KPs and their partners, spouses, and children;(2) Increase sustained demand for HIV and social services;(3) Strengthen systems and the enabling environment to ensure that GOI at all levels (national, state, districts) and civil society representatives have the capacity (tools and skills) necessary to scale up evidence-based, cost efficient and effective models; and to plan and monitor HIV programs using enhanced strategic information systems; and(4) Promote cost effective assessments and rigorous evaluations and learning to contribute to building a GOI-led response, critical in light of decreasing donor’s funding.

1.4 Approach and Key Support Areas

Intended Results of the Program include:

Outcome 1: Increased accessibility and availability of quality HIV clinical and social services.

Sustaining improvements in the existing national HIV response targeting KPs - the Targeted Interventions (TIs), the Integrated Counseling and Testing Centers (ICTC), and ART clinics (Link ART, Center of Excellence, district hospitals) - and demonstrating and assessing innovative and cost effective models to increase access and availability of quality HIV clinical and social services for KPs, their partners, spouses and children.

Intended Results: (1) Provide client-centered HIV testing services, strengthening risk segmentation and prioritization

of services; (2) Pursue new approaches to addressing the significant age gap of accessing services as global

evidence shows that young KPs are not reached as effectively as older KPs;(3) Support systemic and organizational policy changes needed to demonstrate differentiated care

models, adapted to the specific needs and preferences of the different KPs all towards building a national health system response to address HIV as a chronic illness; and

(4) Demonstrate models to strengthen linkages between health and social services providers. Increasing access to social services including social protection schemes, is critical to improving

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adherence to treatment among HIV+ children, adolescents, and adults and to preventing HIV infection.

Outcome 2: Increased and sustained demand for quality HIV services

As India’s guidelines for Test and Start are being rolled out and new enhanced outreach models are being demonstrated, increased availability of and access to HIV services along the cascade is expected (testing, treatment, prevention including introducing PrEP) for KPs, their partners, spouses and children. However, improved uptake and adherence requires complementary interventions that increase awareness and understanding, including accurate information and demand for the different services offered along the cascade.

Increasing Treatment Literacy

Intended Results: Improving understanding and knowledge of treatment literacy and high-impact prevention interventions, including Positive Living, Positive Prevention, PrEP and Opioid Substitution Therapy for KPs, partners and spouses.

Socio-Behavior change communication (SBCC)

Intended Results: providing technical assistance in revising NACO’s SBCC strategy to improve targeted messages, tailored to KPs typology, age, with a focus on young KPs and men (MSM, Male and FSW) and TG.

Community Accountability Systems

Intended Results: This activity will strengthen community-based monitoring systems, all in an effort to ensure that KPs, partners, spouses and children have access to quality HIV services according to their rights, and that KPs and families know where to get the best services.

Increasing Knowledge of Rights

Intended Results: This activity will ensure that KPs, their partners and spouses are aware of policies and their rights to access HIV services. This effort will require coordinated efforts across stakeholders (health and social entities) to ensure demand for comprehensive HIV and health services across KPs, partners, spouses and children.

Outcome 3: Strengthened systems and enabling environment

A robust, decentralized structure from national, to state, to district of the National AIDS Control Program is essential to ensure rapid scale up while fostering innovations at district and service delivery points.

Intended Results:

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(1) Foster a strategic approach in collaboration with NACO at all levels, to strengthen the State AIDS Control Society and District AIDS Prevention Control Units capacity to plan, budget, monitor service delivery, and manage data use at the sub-national level.

(2) Provide technical support to the GOI to improve the Strategic Information Management System, and strengthen data systems to track KPS and their partners, spouses and children all along the continuum of HIV services.

(3) Build NACO’s capacity as a steward of the private sector, building on lessons learned from previous USAID investment in harnessing private sector engagement in TB programming.

(4) Demonstrate how best to improve the attitudes and practices of health care providers, leveraging GOI’s capacity building investments by developing standardized tools and monitoring systems to inform stigma reduction efforts, progress and trends.

Outcome 4: Enhanced learning and cost effectiveness

This project will propose a rigorous learning agenda for implementation at start up. It is crucial that every step of the implementation is monitored and evaluated periodically to ensure unsuccessful approaches are redirected promptly. Documentation of both successes and failures is important as the model is handed over to the GOI for replication and scale up.

Intended Results:

(1) Support building the skills of NACO in analyzing delivery of services systems, testing changes and scaling up changes that resulted in improvements, all based on a rigorous analysis of data.

(2) Exchange learning across districts, states and at national level, among civil society, government and private sector, to bolster a “learning and innovative” approach to continuously improve programs tailored to KPs, their partners, spouses and children.

2. RECOMMENDED THRESHOLD DECISIONS AND MITIGATION ACTIONS

Recommended Action: Categorical Exclusion and Negative Determination with Conditions (Please refer to Summary Section)

All activities under the project consist of technical assistance, training, mentoring, monitoring and evaluation. The table below lists all the activities according to Reg. 216 requirements and recommends Threshold Decisions and environmental compliance actions.

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S. No.

Components and illustrative activities Effect on Natural or Physical environment or Climate Change

Threshold Decisions and Reg. 216 Actions Required

1 Increased accessibility and availability of quality HIV clinical and social services.

a) Sustaining improvements in the existing national HIV response targeting KPs - the Targeted Interventions (TIs), the Integrated Counseling and Testing Centers (ICTC), and ART clinics (Link ART, Center of Excellence, district hospitals) –

b) Demonstrating and assessing innovative and cost effective models to increase access and availability of quality HIV clinical and social services for KPs, their partners, spouses and children.

-Potential impact under this category falls within the increased accessibility and availability of clinical HIV services. All other results are not anticipated to have any negative effects/impacts on the environment.

-Other potential impact could be obsolete pesticides, stored in leaking drums or torn bags, can directly or indirectly affect the health of HIV patients who comes into contact with them. During heavy rains, leaked pesticides can seep into the ground and contaminate the groundwater. Poisoning can occur through directcontact with the product, inhalation of vapors, drinking of contaminated water, or eating of contaminated food. Other hazards may

Categorical Exclusion: Negative Determination with Conditions only for the results increasing accessibility and availability of clinical HIV services. The activity can go forward after the implementer develops selection criteria including environmental and social screening. Eligibility and selection criteria, ERC and Environmental Mitigation and Monitoring Plans (EMMPs) that confirm/do not confirm a potentially significant adverse effect. If confirmed, a Scoping Statement (SS) and Environmental Assessment (EA) will be done by the implementer prior to start of the activity. Terms of Reference (TOR) for SS and EA report will be reviewed by the MEO in consultation with the BEO/Asia

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S. No.

Components and illustrative activities Effect on Natural or Physical environment or Climate Change

Threshold Decisions and Reg. 216 Actions Required

include the possibility of contamination as a result of inadequate disposal such as burning or burying.

2 Increased and sustained demand for quality HIV services

Interventions include creating and improving awareness and understanding, including accurate information and demand for the different services offered along the cascade.

a) Increasing Treatment Literacy b) Socio-Behavior change communication

(SBCC)c) Community Accountability Systemsd) Increasing Knowledge of Rights

No effect Categorical Exclusion: No action required

3 Strengthened systems and enabling environment

Technical support to the GOI to improve the

a) Strategic Information Management System

b) Strengthen data systems to track KPS and their partners, spouses and children all along the continuum of HIV services.

No effect Categorical Exclusion: No action required

4 Enhanced learning and cost effectiveness

a) Monitoring and Evaluation support- building

No effect Categorical Exclusion: No action required

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S. No.

Components and illustrative activities Effect on Natural or Physical environment or Climate Change

Threshold Decisions and Reg. 216 Actions Required

the skills of NACO in analyzing delivery of services systems, testing changes and scaling up changes that resulted in improvements,

b) Exchange learning across districts, states and at national level, among civil society, government and private sector, to bolster a “learning and innovative” approach to continuously improve programs tailored to KPs, their partners, spouses and children.

As a part of this project, the implementation partner will be encouraged to include training on environmental awareness in its capacity building efforts for the GOI, NACO, state and district centers.

3. MITIGATION, MONITORING & EVALUATION:

3.1 Specific Responsibilities: The Agreement Officer’s Representatives (AOR) of the individual projects, with assistance from MEO/DMEO, shall ensure environmental conditions set forth in this IEE are fully transposed into procurement instruments, implemented, reported and timely overseen. In addition, the AORs will ensure that appropriate environmental guidelines are followed, mitigation, monitoring and reporting measures in the IEE are implemented, and that adequate monitoring and evaluation protocols are in place to ensure implementation of mitigation measures.

The Development Objective (DO) Team will ensure that environmental compliance language from the IEE is translated into procurement documents and contracts.

The Mission Environmental Officer (MEO) will provide guidance to ensure that conditions in the IEE are met.

The implementing partners shall have adequate technical and financial capabilities to ensure that all activities conducted under this program comply with the conditions established in this IEE. Implementing partners will also ensure that their project or activities comply with the approved Mission IEE in the country where the project is being implemented. In addition, the recipient must comply with host country environmental regulations and international environmental obligations unless otherwise directed in writing by USAID. In case of conflict

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between host country and USAID regulations, the latter shall govern. Implementers will notify USAID if activities are found to have unintended consequences or mitigation measures are ineffective.

Activities that are not in compliance with approved environmental documentation will be modified or terminated. If activities are found to have unintended negative consequences or mitigation measures are not effective, then activities need to be modified and/or mitigation measures need to be modified.

3.2 Reporting requirements:

The Agreement(s) with the Implementer(s) shall include a requirement to follow all recommendations of this IEE. The Implementer(s) should train key staff, grantees, subcontractors, and beneficiaries on the agreement’s environmental requirements and for ensuring their compliance with these requirements.

The Implementer(s) will have the following documentation and reporting requirements associated with the environmental compliance:

● On a quarterly basis, provide an environmental report, which identifies which, if any, activities have an environmental impact and what steps are being taken to mitigate environmental damage as a result of project activities.

● Final Report will have a section that will summarize program activities related to environmental compliance and will describe results, including information on any positive or negative environmental effects of program activities.

4.LIMITATIONS OF THE IEE:

This IEE does not cover activities involving:

● Assistance for the procurement, use or recommendation for use of pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials;

● Activities involving support to wood processing, agro-processing, industrial enterprises, and regulatory permitting;

● Assistance, procurement, or use of genetically modified organisms (GMOs);● DCA programs;● Procurement, or use of Asbestos, Lead, Arsenic, Mercury Containing Materials (ACM) (i.e. piping,

roofing, etc.), PCB containing transformers, or other hazardous/toxic materials for construction projects; and

● Procurement, use and/or disposal of equipment containing and/or generating low radioactive materials and wastes.

None of these actions are envisioned. Any of these actions would require an amendment to the IEE and its approval by the BEO/OAPA.

5. REVISIONS

Pursuant to 22 CFR 216.3(a) (9), if new information becomes available which indicates that activities to be funded under the HIV Services for Key Populations Affected by HIV/AIDS might be “major” and their effects “significant,” this determination will be reviewed and revised by USAID/India and submitted to the Bureau Environmental Officer (BEO) for approval, and, if appropriate, an environmental

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assessment will be prepared in accordance with the procedures stipulated in 22 CFR 216. It is the responsibility of the AOR to timely inform the MEO and BEO of any changes in the scope and nature of the approved activities, which may warrant the revision of the approved Threshold Decisions. The Bureau Environmental Coordinator has authority to approve IEEs under 22 CFR 216.3(a) (2).

ANNEXURE -1

Environmental Review and Assessment Checklist

Environmental Screening Report: Activities screening results, and recommended determinations.

The Environmental Screening Report presents the environmental issues associated with the proposed activities. It documents mitigation and monitoring commitments. Its purpose is to allow the implementer and USAID to evaluate the likely environmental impacts of the project.

All the results will have to comply with the respective country’s approved IEE requirements.

Sl. No.

Proposed results

Screening Result Recommended Determinations(complete for all moderate/unknown and high-risk activities)

Very Low Risk

High Risk*

Moderate risk or unknown*

No significant adverse impact

With specified mitigation, no significant adverse impact

Significant adverse impact

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2

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3

4

5

*These screening results require completion of an Environmental Review Report.

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APPROVAL OF ENVIRONMENT ACTION RECOMMENDED Clearances:

Project Manager Date:

Deputy Mission Environmental Officer

Sara Heydari

Regional Environmental Adviser for CSA & OAPA

Chandan Samal

Cleared by Email

Date:

January 8, 2018Andrei Barannik Date:

Program Office Director

Regional Legal Advisor

____________________________ Cheryl Williams

Date:

______________

Deputy Mission Director

Diana Weed

Date:

Mission Director:

Ramona M. EL Hamzaoui

Date:

Mark A. White

Concurrence:

Bureau Environmental Officer/Asia : Date:

Will Gibson

Cc: project file, MEO tracking, OAA, RLO