initial environmental examination for usaid/nigeria ... · these activities will not have adverse...

Nigeria Economic Growth & Environment (EGE) DO 2 IEE

INITIAL ENVIRONMENTAL EXAMINATION

FOR

USAID/NIGERIA DEVELOPMENT OBJECTIVE 2:

Economic Growth and Environment (EGE) Office & Portfolio

Program Title: USAID Nigeria Development Objective 2: Broadened, Diverse and Inclusive Private

Sector-Led Growth

Country/Region: Nigeria, West Africa

USG Foreign Assistance Framework Area Covered:

Functional Objective 4: Economic Growth

Program Area: 4.2: Trade and Investment

Program Element 4.2.1: Trade and Investment Enabling Environment

Program Element 3.2.2: Trade and Investment Capacity

Program Area: 4.3: Financial Sector

Program Element 4.3.1: Financial Sector Enabling Environment

Program Area: 4.4: Infrastructure

Program Element 4.4.1: Modern Energy Services

Program Element 4.4.3: Transport Services

Program Area: 4.5: Agriculture

Program Element 4.5.1: Agricultural Enabling Environment

Program Element 4.5.2: Agricultural Sector Capacity

Program Area: 4.8: Environment

Program Element 4.8.2: Clean Productive Environment

Funding Begin: October 01, 2013

Funding End: September 30, 2019

LOP Amount: $250 million (est.)

IEE Prepared By: Nduka Okaro, Nigeria Mission Environmental Officer, Walter Knausenberger,

AFR/SD Sr. Reg. Env Policy Adv., and James Jolley, The Cadmus Group

Current Date: December 13, 2013. Revision July 1, 2014

IEE End Date: December 31, 2019

IEE Amendment (Y/N): No, this updates and replaces the AO2 IEE “Nigeria_EGE_IEE_050710”

Other Relevant Environmental Compliance Documents: 1. “Pesticide Evaluation and Safer Use Action Plan: Maximizing Agricultural Revenue and Key Enterprises in

Targeted sites II (Nigeria MARKETSII PERSUAP_2013_2017)” approved 07/26/2013.

See http://gemini.info.usaid.gov/egat/envcomp/repository/doc/39371.docx.

2. IEE for Nigeria Development Credit Authority (DCA) Renewable Energy. See

http://gemini.info.usaid.gov/egat/envcomp/repository/doc/39936.docx

3. IEE for buy-in to USAID/E3 Renewable Energy Leader with Associates Agreement (LWA) with Winrock

International, see http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/2019.pdf. Superseded by this IEE.

4. RCE for buy-in to E3 Private Financing Advisory Network (PFAN), 2010-2015,

http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/37257.pdf. Superseded by this IEE.



http://gemini.info.usaid.gov/egat/envcomp/repository/pdf/2019.pdf



ENVIRONMENTAL ACTION RECOMMENDED: Categorical Exclusion: X Negative Determination: _X__

Positive Determination: potential Deferral _X___

ADDITIONAL ELEMENTS:

Conditions: X | EMMP: X DCA/GDA: X | PVO/NGO: X | Pesticides:* X

*22 CFR 216.3 (b)(1) applies. MARKETS II PERSUAP in place.

SUMMARY OF FINDINGS:

This Initial Environmental Examination (IEE) provides, in accordance with 22CFR216, the first review of

the reasonably foreseeable effects on the environment of all the activities of the USAID/Nigeria

Economic Growth and Environment (EGE) office, the Development Objective Two: “Broadened, Diverse

and Inclusive Private Sector-led Growth” and will be implemented under the Country Development

Cooperation Strategy (CDCS), October 2013 – September 2018. These activities are grouped under three

intermediate results IR 2.1: Agricultural Competitiveness Increased; IR 2.2: Energy Access

Increased and IR 2.3: Enabling Environment Improved.

The three intermediate results also align with USG Foreign Assistance Framework Economic Growth Objective

in five program areas of Trade and Investment; Infrastructure; Agriculture and Environment. It is expected that a

number of activities from the preceding Assistance Objective 2 (AO2): “Increased Rural Incomes and Jobs in

Assisted Areas” will continue under the new Development Objective. This IEE therefore evaluates both current

and anticipated Economic Growth and Environment Office activities. It also sets out project-level implementation

procedures intended to assure that the conditions in the IEE are translated into project-specific mitigation

measures, and to assure systematic compliance with this IEE during project and program implementation. These

procedures are themselves a general condition for approval of this IEE, and their implementation is therefore

mandatory.

The Nigeria Energy sector activities, interventions and transactions are part of the Agency’s five-year

Power Africa Initiative, which presently covers six bilateral countries and three regional offices.

USAID’s Power Africa program is the subject of an umbrella Programmatic IEE (P-IEE) conducted to

inform the planning and implementation of all of Power Africa in sub-Saharan Africa. Initially, the

Programmatic IEE for Power Africa covers all PA core Operating Units and classes of action at an

“umbrella” level. Further, the Nigeria EG sector’s IEE analysis of the specific energy activities being

planned and undertaken by USAID/Nigeria is consistent with the expected supplemental country-specific

analysis called for by the P-IEE, so that country-specific environmental review and environmental

mitigation and monitoring are undertaken at the appropriate points.

Scope. This IEE addresses the entire portfolio of activities anticipated under the USAID/Nigeria

Economic Growth & Environment (EGE) portfolio. Replacing and superseding the Mission’s previous

EG IEEs, it applies to all economic growth activities implemented under Nigeria’s 2013-2018 CDCS

Development Objective 2, except that (1) ongoing activities operating an approved environmental

mitigation and monitoring plan (EMMP) may continue operating under that EMMP; and (2), activities

funded via an existing buy-in mechanism will be subject to and implemented in accordance with the

approved IEE covering that mechanism. Further, the IEE for Nigeria Development Credit Authority

(DCA) Renewable Energy is still in force and consistent with this DO EGE IEE, as well as the

MARKETS II PERSUAP.

Based on the environmental review presented in this IEE, the following determinations are made:


Categorical Exclusion in pursuant to 22 CFR 216.2(c)(2) is recommended for the following activities in

support of agricultural competitiveness: improved energy access and improved enabling environment.

These activities will not have adverse effects on the environment as detailed in Table 1.

(i) Activities involving education, training, technical assistance or training programs except to the

extent such programs include activities directly affecting the environment (such as construction of

facilities, etc.);

(ii) Activities involving controlled experimentation exclusively for the purpose of research and field

evaluation and carefully monitored;

(iii) Activities involving analyses, studies, academic or research workshops and meetings;

(v) Activities involving document and information transfers; and

(viii) Programs involving nutrition, health care, or family planning services except to the extent designed

to include activities directly affecting the environment (such as construction of facilities, water

supply systems, waste water treatment, etc.);

Negative Determinations with conditions are recommended for the following sorts of activities:

Per 22 CFR 216.3 (a) (2) (iii):

Strengthen the capacity of local agro-business organizations to improve distribution

Formation of major seed and fertilizer alliances to increase supply of inputs

Promote use and adoption of available improved seed/varieties sustainable water/soil

management and post-harvest technologies

All pesticide-related activities referenced in MARKETS II PERSUAP

Commercialization and Post-Harvest Activities (food processing)

Construction of water catchments and small scale irrigation technologies to provide irrigation and

potable water

Small scale construction of food storage warehouses and cold storage facilities

Aquaculture

Provision of agricultural credit guarantees via NIRSAL

Technical assistance to DCA-supported SME loan facility for agricultural value chain

development

Technical assistance to Power Africa-related DCA loan portfolio guarantee (LPG), portable

guarantee (PG) or loan guarantee agreements between international and local commercial bank(s)

to support, e.g., (a) capital expenditure needs of recently privatized generation and distribution

companies in Nigeria, (b) financial risk mitigation in loaning to a solar leasing company (Amp

Ventures) seeking to deploy throughout Nigeria, and (c) others to be determined.

T.A. for GDA through PFAN

Sub-grant Activities (Project Development Facility and Innovation Funds).

Synopsis of Recommended Determinations. Activities Categorically Excluded from further

environmental review are not listed, for the most part. See Table 1 in IEE narrative.

Illustrative Activity ND/C Potential PD Deferral Link to

Analysis

IR 2.1 -- Agricultural Competitiveness Increased

Strengthening the capacity of local agro-business

organizations to improve private sector distribution

of inputs.

X Click here

Use and adoption of improved seed,

sustainable agriculture practices and potentially

X Click here



Analysis

profitable post-harvest technologies.

Support activities addressing warehouse receipt,

agricultural commodity trading and accessible

market information systems; meeting market

standards.

X Click here

Support activities addressing public and private

investments that advance agricultural value chain

and efficient agricultural marketing such as storage

facilities, cold storage, packaging facilities, and

agricultural processing facilities.

.

X

Click here

Conduct value chain analysis of major targeted

commodities such as rice, maize, cassava, soybean,

sorghum and aquaculture.

X Click here

Construction of water catchments and small scale

irrigation technologies to provide irrigation and

potable water and

X Click here

Promotion of the production and utilization of

cowpeas, shea nuts, poultry, small ruminants,

vegetables or other nutritionally important and /or

marketable products

X Click here

Administer grant funds: (a) Innovation Fund

(b) Project Development Facility Fund

X Click here

Develop small-scale storage sheds to store crops

and other commodities for later sale or for use as

collateral towards credit or insurance

X e

Click here

Support food Processing and packaging to

significantly reduce in current wastage and ensure

extended access

X

Procurement, use, promotion of, or training use of

pesticides, including herbicides, and fungicides.

X X Click here

Activities involving the field testing or open release

of genetically modified organisms (GMOs)

X Click here

IR 2.2 -- Energy Access Activities

Assist in privatizing existing state energy

companies, developing the frameworks and

promoting projects for private investment in energy

resources exploration and production, processing

and conversion, transmission and transportation,

and distribution and delivery of energy to end-users

Cat. Ex.,

unless FI1

involved,

then ND/C

Click here

DCA loan guarantees and T.A.

Nigeria Promoting Renewable Energy and Energy

Efficiency Project.

Component 1: DCA instrument to provide partial

credit guarantees to local Banks to increase debt

financing to the clean energy sector.

X

X

Click here

1 FI = Financial intermediation



Analysis

Component 3: T.A. for the successful

implementation of the Energy sector activities. .

X

Nigeria Promoting Renewable Energy and Energy

Efficiency Project.

Component 2: GDA with the Private Financing

Advisory Network (PFAN),

X

Click here

Participate in power generation while also building

the capacity of the electricity regulator to

effectively regulate and incentivize the private

sector participation in the power sector.

X

PD could apply, if

“participation”

includes support

of construction

Click here

IR 2.3 -- Enabling Environment Activities

Support Corridor Management Group (CMG) to

improve coordination along the Lagos—Kano—

Jibya transportation corridor connecting the port of

Lagos with the inland countries of Chad, Niger and

Burkina Faso.

Cat. Ex, but

if includes

FI, then

ND/C

If “support ”

includes support

of actual

construction, then

PD could apply

Click here

Provide technical assistance to the GON on voltage

management and liberalization of the power

sector.

If includes

FI, then ND

w conditions

: Click here

Provision of Agriculture credit guarantees by

working with the Nigeria Incentive-Based Risk-

Sharing System for Agricultural Lending

(NIRSAL).

X Click here

Provide technical assistance to financial institutions

who house the DCA guarantee for investment in

small and medium renewable and energy efficient

companies; agro processing, and warehousing

companies, and public and private facilities willing

to retrofit facilities with clean energy.

X Click here

Monitoring and Implementation

In addition to the project-specific conditions enumerated in Section 4, the negative determinations

recommended in this IEE are contingent on full implementation of the following general monitoring and

implementation requirements:

These require:

1. Implementing Partner briefings by DO team in collaboration with the MEO on Environmental

Compliance Responsibilities during the post award conference;

2. Development of environmental mitigation and monitoring plans (EMMPs) for projects with at

least one negative determination with conditions;

3. Each Implementing Partner shall integrate their EMMP into their project work plan and budgets,

implement the EMMP, and ensure a project reporting that tracks EMMP implementation.

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


5. Assurance of sub-grantee and sub-contractor have capacity to implement and monitor IEE & EA

conditions;

6. The extended EGE DO Team (incl. implementing partners) have environmental management

capacity to ensure compliance;

7. As part of its work plan and all annual work plans thereafter, IPs, in collaboration with their

COR/AOR, shall review all on-going and planned activities to determine if they are within the

scope of this IEE, and

8. Compliance with host country requirements.

Annexes:

Annex 1: List of the awards that are active @ September 30, 2013

Annex 2: Washington/Regional Related IEEs

Annex 3: USAID Africa Bureau Fertilizer Information Sheet

Annex 4: DCA Loan Agreement Conditions

Annex 5: Environmental Mitigation and Monitoring Plan (EMMP) Template Annex 6: Environmental Screening Form for Sub-grant/New Activities Proposed under USAID/Nigeria DO 2 Annex 7: Draft Environmental Mitigation and Monitoring Plan for Small scale water supply

Annex 8: Category of Mandatory EIA studies in Nigeria

Annex 9: Standard Chartered Bank (UK) and Zenith Bank Nigeria Environmental and Social Responsibility

Policies


APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:

CLEARANCE:

Mission Director: ____________/s/________________ Date: _02/13/2014___

Michael T. Harvey

CONCURRENCE:

Africa Bureau Environmental Officer: ________/cleared/__________________ Date: __08/07/2014__

Brian Hirsch

Approved: ____X_______

Disapproved: ____________

Filename: Nigeria_DO2_Econ_Growth_Env_IEE_080714.

REA/WA Tracking Number: NG-13

ADDITIONAL CLEARANCES:

Economic Growth and Environment Director: _________/s/_____________ Date: __12/19/2013__

Sharon Pauling

Regional Environmental Advisor (USAID/WA): ______/s/_____________ Date: 02/09/2014___

Jody Stallings

Mission Environmental Officer: ______________/s/_________________ Date: ___12/16/2013___

Nduka Okaro

APPROVAL OJF ENVIRONMENTAL ACTION RECOMMENDED:

CLJEARl\NCE: ' I .

Mission Director: Date: .·; :.. :· =~· / ,.. " --------Michael Harvey

CONCURRENCE:

Brian Hirsch u Approved:

Disapproved: _ _ _ _ _

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OPTIONAL CLEARANCE:

General Counsel (Africa Bureau): __ _,_}J"""""4}_:/k.._ ..:._ _____ Date: I

ADDITIONAL CLEARANCES:

Date:_~ I/

Sharon Pa\iliug

Regional Environmental Advisor (USAID/WA): .;,, ;~.,. i-:,; :J,_·:;,y~..._,;... ·:.t ~ Date: o:;..: / c - I 7.. t/~· . , ~, ,. . ' - - - --

Jody Stallings

Mission Environmental Officer: ___ JL_cl_\ _ _ ~~t'i-_1 _____ _ Date: _ i _ / I:, l: _ _ -:i

Nduka Okaro

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Nigeria Economic Growth & Environment (EGE) DO 2 IEE Page 8

INITIAL ENVIRONMENTAL EXAMINATION

Program Number and Title: USAID Nigeria Development Objective 2 IEE: Broadened, Diverse

and Inclusive Private Sector-Led Growth

Country/Region: Nigeria, West Africa

1.0 BACKGROUND AND ACTIVITY DESCRIPTION

1.1 Purpose and Scope of the IEE

In accordance with 22 CFR 216, this IEE reviews the reasonably foreseeable effects of each activity on

the environment. On this basis, the IEE recommends Threshold Decisions and in some cases attendant

conditions for these activities. This IEE is specific to the Economic Growth and Environment (EGE)

Office as Development Objective Two (DO2) under the USAID Nigeria FY2014 – FY2018 CDCS. DO2

emphasizes USG activities in Nigeria to increase agriculture competitiveness necessary to support

sustainable, diverse, and inclusive economic growth. The interventions will support farmers, private

sector farm inputs dealers, agro-processors and expanding trade and transportation along a South-north

trade corridor. Household and community resilience as well as increasing energy access are supported.

The DO2 activities are grouped in three intermediate result areas, namely Agricultural Competitiveness

Increased; Energy Access Increased and Enabling Environment Improved. They also align with the

following Foreign Assistance Objective 4: Economic Growth; Program Areas 4.2 (Trade and Investment)

4.3 (Financial Sector), 4.4 (Infrastructure), 4.5 (Agriculture) and 4.8 (Environment).

This IEE synthesizes current and anticipated Economic Growth and Environment Office activities under

the office’s various programs and projects into a set of intervention categories, each of which contains a

number of entailed activities. Of the 14 current USAID/DO2 activities listed in Annex 1, 7 are either field

support, regional buy-in or centrally funded and the other 7 are directly managed within USAID/DO2

team. The field support and centrally funded activities fall under separate approved Initial Environmental

Examinations (IEEs). For example, field trials are addressed in the IEE approved by EGAT/ESP on July

19, 2010 for the Field trial of Bioengineered Cowpea Resistant to Maruca Pest and an amended version

approved by the Bureau for Food Security (BFS) Environment Officer on August 09, 2011. The Regional

buy-in of the West Africa Seed Program (WASP) IEE was approved by the Afr. Bureau Environment

Officer on July 06, 2012 (Annex II)

This IEE covers USAID/DO2 active awards or awards likely to be extended beyond September 30, 2013

by the following Implementing Partners (IPs):

1. Chemonics International Inc.

2. International Centre for Energy, Environment and Development (ICEED)

3. CARANA Corporation

4. Catholic Relief Services (CRS)

5. United States Department of Agriculture (USDA)

6. National Association of Regulatory Utility Commissioners (NARUC)

7. International Food Policy Research Institute

8. Nexant, Inc.

9. Monitor-Deloitte

10. Winrock


11. DCA with Eco Bank Nigeria

12. DCA with First Bank Nigeria and Zenith Bank Nigeria.

13. TBD (New Awards)

A list of the bilateral awards that are active and/or planned during the period May 2010-September 2014

is attached (Annex 1), and while additional bilateral activities may be designed during the next few years

as the program under the CDCS evolves, the majority of USAID DO2 activities will continue to be

implemented using the existing mechanisms.

The IEE also sets out project-level implementation procedures intended to assure that the conditions in

the IEE are translated into project-specific mitigation measures, and to assure systematic compliance with

this IEE during project and program implementation. These procedures are themselves a general

condition for approval of this IEE, and their implementation is therefore mandatory.

1.2 Background and Activity Description

Nigeria has enjoyed relatively strong economic growth over the past eight years but poverty remains a

major concern, with 61.2 percent of the population living below the poverty line. While oil accounts for

95 percent of export earnings and 85 percent of government revenues, agriculture, undoubtedly remains

the most important sub-sector in the Nigerian economy next to petroleum, employs 70 percent of the

population, but accounts for only 2.6 percent of exports. Many West African countries are landlocked and

rely heavily on neighboring countries for food. Due to Nigeria’s geographic location, fertile land, and

government commitment to strengthening the agricultural sector, the country can become an important

player in regional food security and trade. Further, economic growth in Nigeria remains constrained by

inadequate infrastructure and electricity, policies that inhibit private sector investment, insufficient water

and sanitation facilities, and poor access to quality education. While the bulk of the water and sanitation

activities are under the Investing in People Health Area, provision of the services to vulnerable

populations and agro-processors are covered in this IEE.

Rural areas suffer more from lack of basic infrastructure. This trend further exacerbates the decline in

living standards in rural areas and translates into increased levels of poverty. Poor rural road

infrastructure negatively impacts on agricultural profitability and productivity, the associated higher

transportation costs to carry goods to markets, limited access to inputs, and increased crop spoilage are of

great concern.

The Sustainable, diverse and Inclusive Economic Growth Development Objective builds on EGE’s draft

Multi-Year Feed the Future (FTF) Strategy (2013-2018) prepared in November 2012 and the analyses and

consultations conducted during its preparation. This draft strategy identified three “core investment

areas:” (1) transforming value chains, (2) addressing vulnerabilities, and (3) improving the enabling

environment. Over the past two decades agricultural yields have remained relatively stagnant, with

increases in production more due to expanding land under cultivation, rather than gains in yield. Yields

have remained very low; however, the increased yield observed in USAID targeted areas is indicative of

potentials for increased yield in Nigeria.

Nigeria’s lack of sufficient electrical power is one of the biggest hindrances to economic development.

Currently, Nigeria generates 50 percent below its installed capacity of 6,000 megawatts (MW) for a

population of more than 170 million people. This leads to chronic power shortages and widespread use of

inefficient small generators to meet energy demands. Businesses may spend between 30-40 percent of

their revenue on diesel to power generators. Without a significant increase in electricity supply, Nigeria’s

other efforts to create growth, reduce poverty and contribute to reducing conflict in the country will have


limited impact.

USAID Nigeria is one of six core Missions whose energy sector interventions and transactions are

contributing to the Agency’s five-year Power Africa Initiative to support economic growth and

development by increasing the supply of and access to reliable, affordable and sustainable power in sub-

Saharan Africa. USAID is providing targeted T.A. to the key energy sector actors such as the Nigeria

Ministry of Finance, PPP Unit, and the Transmission Company of Nigeria. It is also buying in to the

Power Africa Transactions and Reform Program (PATRP) contract.

The following is a description of each intermediate results and illustrative activities. Activities with

physical intervention on the environment will be implemented across the national six geo-political zones

and nearly 20 out of the 36 states in Nigeria. (Annex 1)

1.3 ACTIVITY DESCRIPTION

1.3.1 Agricultural Competitiveness Increased ( IR 2.1)

Increasing agriculture competitiveness is necessary to support broadened, diverse, and inclusive private

sector-led growth as most of the population depends on agriculture for employment. To become

competitive, agriculture productivity must increase. Interventions to support this include assistance to

farmers, support for private sector provision of farm inputs, and support to agro-processors. The focus

will be on the alignment of Mission activities with the priorities of the Nigerian government’s Agriculture

Transformation Agenda.

This specifically involves (1) working with target value chains, rice, cassava, sorghum, cocoa, and

aquaculture. (In addition, maize and soy will be treated as sub-value chains as they are major ingredients

of fish feed, the cost of which is a major constraint in aquaculture.) Interventions will provide

smallholders with access to better inputs, such as seed and fertilizer, adequate finance, better water

management, appropriate technology, and extension services, and link farmers with pre- and post-harvest

private sector processors and producers. (2) Supported in expanding agricultural trade by improvements

in custom and trade facilities; and provision of business development services, particularly for firms

wishing to export Nigerian products. (3) Increased household and community resilience, with a particular

focus on women’s contributions, supports agriculture competitiveness, as much of this depends upon the

ability of households and communities to increase their nutritional and financial well-being, allowing

them to respond better to external and internal shocks, increasing agricultural productivity and quality of

produce over time thereby entering commercial markets. (4) Private sector participation in all segments

of the agricultural value chain is critical to increasing competiveness. (5) Due to the large capital outlay in

funding feeder roads and large irrigation projects, USG interventions will be limited to preliminary

studies and design work in support of the feeder roads projects sponsored by the World Bank and AfDB.

Illustrative Activities:

Strengthening the capacity of local agro-business organizations to improve private sector distribution of

agricultural inputs, and formation of major seed and fertilizer alliances toward increase the supply of

quality seed, fertilizer, and other inputs to millions of small-holder farmers and stimulate productivity

increases.

Enhancement of the capacities of small and medium agro-enterprises, producer organizations/associations,

(male and female) through training to increase businesses and entrepreneurial skill, contract negotiations,

product management, and organizational governance.


Promotion of the use and adoption of available improved seed/varieties of target crops; sustainable soil and

water management practices (e.g. drip irrigation, improved fallows, and inorganic and organic fertilizer

application, integrated pest management techniques, small irrigation technologies and management); and

potentially profitable post-harvest technologies.

Support activities addressing warehouse receipt, agricultural commodity trading and accessible market

information systems; meeting market standards; and public and private investments that advance

agricultural value chain and efficient agricultural marketing such as storage facilities, cold storage,

packaging facilities, and agricultural processing facilities.

Support the transfer and adaptation of proven technologies and human organization innovations to increase

market access, food or cash transfers in exchange for public works; and resource transfers and/or

agricultural inputs (e.g. seeds, tools, and livestock) which enable male and female producers to try new

technologies and production methods that would otherwise not be available to them

Conduct value chain analysis of major targeted commodities such as rice, maize, cassava, sorghum, and

aquaculture; expanding new multi-partner value chain alliances; and increasing business capacity of

agricultural firms.

Support construction of water catchments to provide irrigation and potable water and encourage farmers to

rear small stock that require less feed and support agro-processors water supply need within targeted

commodity value chains.

Support marketing campaigns to improve the visibility and raise awareness of Nigeria’s products and

branding. Production of marketing materials and educational guides needed to raise awareness and

understanding of market information systems.

Support nutrition education and awareness, introduction of more nutritious and fortified foods;

collaboration with the HIV/AIDS and Tuberculosis Office on the procurement and distribution of fortified

foods.

Promotion of the production and utilization of cowpeas, shea nuts, poultry, small ruminants, vegetables or

other nutritionally important and /or marketable products that do not require large land areas and are often

classified as poor people’s or women’s activities;

Procurement, use, promotion of, or training use of pesticides, including herbicides, and fungicides.

Conduct performance and impact evaluations of targeted value chain interventions and studies on

diversified economic opportunities to demonstrate innovations and technologies that reduce women’s labor

burden and/or increase productivity of labor.

Administer grant funds: (a) Innovation Fund to promote innovative applications (ideas, processes,

equipment, training, designs) that can be introduced into the commodity value chain to enhance

productivity, increase efficiency, improve a process or otherwise lead to some practical benefit to producers

or to agri-businesses (b) Project Development Facility Fund to provide technical assistance to enterprises

in creating a bankable export business plan, market assessments, bringing products up to international

standards, packaging and labeling requirements, food testing certification, SPS standards, transportation,

marketing and sales.

1.3.2 Energy Access Increased (IR 2.2)

Electricity access is considered to be a significant constraint to development of the private sector, and

unreliable and insufficient supply remains a significant bottleneck to economic growth and agriculture

competitiveness. An increase in demand for energy typically occurs as the commercial agriculture sector


grows. Nigeria’s capacity to produce clean renewable energy is also very limited.

Increasing energy access as measured by household and business access to affordable electricity and

volume of electricity generated and distributed, will be supported through extensive participation of the

private sector and through a diversification of energy sources, to include gas, hydro, wind and solar.

Finally, an improved Energy Sector enabling environment, as described as part of IR 3 below, will

provide the legal & regulatory, capacity strengthening and access to credit reforms to support further

attainment of these results.

These energy sector activities, interventions and transactions are contributing to the Agency’s five-year

Power Africa Initiative to support economic growth and development by increasing the supply of and

access to reliable, affordable and sustainable power in sub-Saharan Africa. USAID Nigeria is one of the

six core countries included in Power Africa, and is providing targeted T.A. to the key energy sector actors

such as the Nigeria Ministry of Finance, PPP Unit, and the Transmission Company of Nigeria. It is also

buying in to the Power Africa Transactions and Reform Program (PATRP) contract.


Assist in privatizing existing state energy companies, developing the frameworks and promoting projects

for private investment in energy resources exploration and production, processing and conversion,

transmission and transportation, and distribution and delivery of energy to end-users

Build the capacity of the Ministry of Petroleum Resources to work with the private sector to end gas flares

in the Niger Delta through the GON Accelerated Gas Development Project (AGDP).

Build the capacity of the electricity regulator to effectively regulate and incentivize private sector

participation in the power sector.

Provide technical support at the state level on the development of renewable energy resources and provide

support to Cross River state on a pilot small hydro project to encourage the generation of clean energy with

plans to expand it across other states with renewable energy resources.

Deployment of energy efficient cook stoves to secondary schools, build the capacity of artisans to produce

these stoves thereby creating employment,

Support an advocacy campaign for the adoption of policies that would create an environment for the stoves

to penetrate the market, and launch a tree planting campaign for afforestation.

Work with Commercial Banks through the use of the Development Credit Authority mechanism to

encourage debt financing for clean energy project.

Illustratively, in 2014, at least two energy sector DCA loan guarantees are being negotiated in Nigeria: (a)

DCA to provide a loan guarantee on a $95 M loan from Standard Chartered Bank to Zenith Bank Nigeria.

The proceeds of the loan will be used to support capital expenditure needs of recently privatized generation

and distribution companies in Nigeria. (b) DCA to provide a loan or portable guarantee (PG) on a ~$40 M

loan from a TBD commercial bank to Amp Ventures. Amp is a solar leasing company seeking to deploy

their model throughout Nigeria by partnering with banks, fueling stations and telecommunications

companies.

Work through the Climate Technology Institute private financing advisory network to mentor clean energy

project developers in preparing bankable business plans for equity financiers.

The Nigeria Promoting Renewable Energy and Energy Efficiency Project takes a three-pronged approach to


developing the renewable energy and energy efficiency markets in Nigeria. The first component of the program

establishes a Development Credit Authority (DCA) instrument to provide partial credit guarantees to local Banks

(initially Eco Bank and First Bank) in order to increase debt financing to the clean energy sector. The second

component is a Global Development Alliance (GDA) with the Private Financing Advisory Network (PFAN), which

will link investors/financiers and clean energy project developers to help produce ‘’bankable’’ project and equity

financing proposals. The third component will provide technical assistance for the successful implementation of the

Renewable Energy Project which will be implemented through an Associate Award (cooperative agreement) under

the USAID/E3 Renewable Energy Leader with Associates Agreement (LWA) with Winrock International.

The technical assistance component of the Renewable Energy Project under the LWA will develop (i) capacity of

financial institutions, particularly the DCA banks, to ensure optimal utilization of the DCA guarantee; (ii) capacity

of companies in the clean energy sector and those in selected sectors seeking to utilize renewable energy, to provide

a pipeline of potential deals for the DCA banks; (iii) capacity of government institutions to encourage the enactment

and implementation of appropriate legislation to incentivize private sector participation in the development of the

clean energy market, and (iv) capacity of vocational training institutes, to strengthen the cadre of non-qualified and

qualified professionals to install, operate, and maintain decentralized renewable energy investments.

1.3.3 Business Environment Reformed (IR 2.3)

An improved enabling environment is at the base of support to achieving the intermediate results and the

development objective. An important component will be the implementation of a policy framework that

encourages increased private sector investment in the agricultural and related sectors (water, energy,

transportation). The GON joined “Grow Africa” in June 2012 and the New Alliance for Food Security

and Nutrition in June 2013. Both initiatives are predicated on the essentiality of private sector investment

for sustainable increase in agricultural sector growth. The Mission’s activities supporting this

intermediate result will focus on policies that support private sector-driven development with the

government playing a regulatory role and building the capacity within the government to conduct

evidence-based policy analyses.

1.3.3.1: Agricultural Sector Enabling Environment:

Agricultural enabling environment in Nigeria has been considered confusing, conflicting, and

counterproductive. Changes in the policy environment are called for to increase private sector

investment. There is insufficient transparency and accountability, limited incentive to mitigate perceived

risk, and relatively high costs for supporting services (i.e. transportation, utilities, and security). Thus the

enabling environment to attract new investment in agriculture is weak, but could quickly improve with

appropriate government intervention. Along with government, , USG will continue to play an important

catalytic role in the policy development process by providing the analytical justification/framework for

changes in existing policies or for adoption of new policies that foster agricultural growth and improve

food security. A national Biosafety Bill, will pave the way for the safe handling, importation, and export

of genetically modified organisms, improved seeds, and consequently enhance Nigeria’s food security.

Enhanced capacity of GON to evaluate and address crucial biotechnology policy issues and to implement

an agricultural biotechnology program is critical.


Conduct a climate change vulnerability assessment to identify gaps and key areas for Mission cross cutting

intervention in adaptation.

Support the Famine Early Warning System Network (FEWSNET), an early warning system that monitors

food security, rainfall, production and postharvest losses in order to prepare for disaster and anticipate the

amount of food aid needed in case of drought.


Support the GON’s Agriculture Transformation Agenda (ATA) through investment prioritization and the

preparation of state agricultural investment plans; conducting research and analysis in key policy areas

including input availability, land governance, water resources and irrigation; and improving knowledge

management and analyses for agricultural planning.

Support public education on key agricultural policies and progress toward developing and implementing

them. Use of media in creating awareness amongst all stakeholders regarding the policy process and the

implementation of policies key to the economic and social resilience. Creation of appropriate mechanisms

and opportunities for vulnerable populations to engage in policy dialogue.

Support the development of specific guidelines and regulations that ensure biotechnology laws are

functional; support the National Biosafety Management Authority (NBMA) to conduct evidence-based

reviews for decision-making; and developing and implementing a strategy for bio-safety outreach and

communication.

Build government capacity to develop agricultural statistics and information systems; introduce best

practices to improve commodity storage and handling to reduce post-harvest losses; and provide technical

assistance to develop a food safety policy.

Build public and private sector capacity to analyze the impact of trade and investment agreements on

economic growth, productivity, employment, poverty, gender equity, fiscal revenues, and other national

and individual male and female stakeholders’ interests.

Support institutions, policies and incentives aimed at ensuring that adequate, safe, and nutritious food is

available; markets function efficiently; and that low-income groups and those vulnerable to food insecurity

(e.g., female farmers with small land holdings, female-headed households, children, and HIV-affected) are

able to access and appropriately utilize that food.

Support public education on key policies and progress toward developing and implementing them. Use of

media in creating awareness amongst all stakeholders and creation of appropriate mechanisms and

opportunities for vulnerable populations to engage in policy dialogue.

Promote public forums at national, state and local government levels for all relevant stakeholders

(including youths and women) around commodity value chain issue and policy changes.

1.3.3.2: Agricultural Trade Enabling Environment:

The overall goal of trade enabling environment is to strengthen trade policy and trade facilitation

environments that promote development of Nigeria’s non-oil export (in particular agribusiness) sectors.

Its purpose is to facilitate creation of an inclusive system of trade policy formulation and implementation

through capacity-building for public and private institutions to drive trade facilitation and trade

competitiveness in Nigeria. A current activity, Nigeria Expanded Trade and Transport (NEXTT) is

supporting GON in three interrelated tasks: capacity building for trade policy formulation and

implementation; support for customs modernization; and support for institutional capacity building on

standards and food safety.


Support trade liberalization. Build the capacity of the public sector to meet requirements for accession to

the WTO and participating effectively in the WTO system and to meet other international agreements such

as the U.S. Free Trade Area agreements and Bilateral Investment Treaties


Provide technical assistance in developing implementing regulations and policies for the new CEMA and

capacity building and training for the Nigerian Custom Service (NCS) to improve its ability to oversee the

new regulatory framework. Provide training in valuation and the use of tools such as scanners to help NCS

attain its goal of internalizing destination inspection services.

Provide training on benchmarking effectiveness of trade facilitation metrics and the implications of these

for customs modernization

Support Corridor Management Group (CMG) to improve coordination along the Lagos—Kano—Jibya

transportation corridor connecting the port of Lagos with the inland countries of Chad, Niger and Burkina

Faso.

Conduct analyses and issue reports supported as necessary by a team of technical experts that explain key

factors impeding or facilitating progress toward access and use of financial services by beneficiaries

1.3.3.3: Energy Sector Enabling Environment:

For energy, enabling environment work will include assistance to the energy sector, which will expand

efforts to privatize the electricity sector and increase independent power production. Reform efforts will

intensify regarding electricity transmission and revenue collection for distribution companies, and

additional efforts to capture flared gas for export and for the domestic market. Much of this will involve

continued attention to technical assistance for relevant governmental agencies responsible for the reform

and post-privatization, and for developing legal, regulatory and financial capacity, and the exploration of

financial backing in coordination with financial institutions for sound, bankable energy projects.

These activities, interventions and transactions are part of the Agency’s five-year Power Africa Initiative.


Provide technical assistance and training to policy makers in the power and oil and gas sector, embedding

an advisor into the Nigerian Bulk Electricity Trading Company to improve its capacity to negotiate, and

procure competitive electricity.

Create a renewable energy regulatory framework, a cost reflective tariff; and improve the regulatory

environment for private sector investments.

Support GON efforts to improve the policy and regulatory environment for clean energy production; reduce

gas flaring and make captured gas available for the generation of clean energy; provide technical assistance

to the GON on voltage management and liberalization of the power sector

Provide technical assistance to financial institutions who house the DCA guarantee; small and medium

renewable and energy efficient companies; agro processing, health care delivery and warehousing

companies, and public and private facilities willing to retrofit facilities with clean energy.

1.3.3.4: Financial Sector Enabling Environment:

Finally, the financial sector must become a full partner in supporting development. Access to credit will

be increased through partial loan guarantees to allow private banks to increase lending. In addition, work

with micro-finance institutions will expand micro-loans. Capacity strengthening for lenders will ensure

they understand the business environment that potential borrowers face in agriculture and energy, and

help ensure a proper flow of information to increase the number of bankable projects. This area will

require significant attention beyond what has been done to date, and will be a focus of this strategy

period. There exist a cross-cutting energy/agriculture loan portfolio guarantee with two guaranteed banks

was recommended addressing limited access to finance constraints in the renewable energy and

agribusiness sectors. The guarantee supports both banks’ expansion into funding projects in agribusiness


(non-renewable energy activities) and renewable energy activities involving solar, biomass, hydro, wind,

clean cook stoves, and energy efficiency activities by small- and medium-sized enterprises (SMEs),

thereby increasing access to finance on positive terms to creditworthy but underserved potential clients. Illustrative Activities:

Increased basic financial, education and entrepreneurial skill development through increased financial

capabilities of men and women in targeted zones, both for targeted and non-targeted value chains.

Continued Technical Assistance and training for producer groups though training and marketing

Provide technical assistance to financial institutions who house the DCA guarantee; small and medium

renewable and energy efficient companies; agro processing, health care delivery and warehousing

companies, and public and private facilities willing to retrofit facilities with clean energy.

Provision of Agriculture credit guarantees by working with the Nigeria Incentive-Based Risk-Sharing

System for Agricultural Lending (NIRSAL).

2.0 Country and Environmental Information (Baseline)

2.1 Nigeria’s Physical and Socio –Economic profile Nigeria has has a vast land area of about 923,770 square kilometers of which about 70 million hectares

are farmland. It is bounded by Cameroon and Chad Republic to the East, Niger Republic to the North

and Benin Republic to the West. The southern coastline is dominated by the delta of the River

Niger. Nigeria is the largest country in tropical West Africa but only the twelfth largest country in Africa,

however, a quarter of the continent’s people live in Nigeria, a greater population than any other African

country.

The nation features a great diversity of ecosystems - from the rainforest through dry savannah to dry lands

and flat coastal zones to plateaus and highlands. It boasts of a few large patches of natural lowland and

montane forests, important freshwater wetlands, savannas, high-altitude plateaus, mangroves, and coastal

areas under various climatic conditions, resulting in an internationally recognized abundance of

biodiversity. Unique primate species like the Cross River gorilla (Gorilla gorilla diehli), the drill

(Mandrillus leucophaeus), and a number of smaller guenons are found only in Nigeria and adjacent forest

areas. An extraordinary diversity of butterflies, amphibians, and other species has been tallied in Nigerian

habitats. Many crop species also originated here, and a diversity of land races still exists in the country.

Surrounding these remnant natural areas are villages, agricultural lands, and cities. As the most populous

country in Africa, Nigeria faces extreme pressures on biodiversity and tropical forests. Wildlife, trees, and

many other plants are over-harvested and poached, and the natural environment faces increased

degradation from expanding unsustainable agriculture, water pollution, air pollution, and a variety of

other anthropogenic factors. Desertification and climate change add to the stress. Lack of information

about the present status of most habitats and species, about the actual extent of protected areas, and about

other key data makes management difficult. Policymakers, managers, and technical staff at all levels need

better information and further training to better fulfill their functions related to biodiversity and forest

conservation and management.

Soils in Nigeria are variable due to variations in the geological for nations and climate. More predominant

in the country is the ultisols which covers about 46% of the total area of the country. Though it is of

moderate to low productivity, it performs very well under good management. Only 6% of the country is

covered by entisol - the high productive soil. Nigeria has also been classified into eight Land Resources


Zones, namely: semi-arid, dry sub-humid. sub-humid, humid, very humid, ultra-humid, plateau and

mountain zones. Most, if not all of these ecological niches have witnessed pressure resulting from

uncontrolled socio-economic activities leaving a large proportion of the land barren.

The intensification of the use of fragile and marginal ecosystems has led to progressive degradation and

continued desertification of marginal agricultural lands even in years of normal rainfall. It is feared that

the damage by drought and population pressure may have resulted in the genetic loss of a vast array of

valuable plant species. Pressure on the dwindling resources in the arid prone areas has caused in a number

of devastating socio-political and sectarian conflicts in the country with concomitant death, injury and

heavy economic losses. Inappropriate agricultural practices, the destruction of watersheds, and the

opening up of river banks and other critical areas have led to silting of river beds and loss of water

courses. Uncontrolled use of agro-chemicals and the concomitant problems of chemical persistence in the

soil in humid areas and soil-crust formation in arid climates have contributed to salinization and

destruction of vast agricultural lands. National policy objective is to evolve sound planning and

management of land resources in the country.

Nigeria has enormous natural resources. It has about 34 different minerals across the country (including

gold, iron ore, coal, tin, uranium, phosphates, and limestone), 37.2 billion barrels of proven oil reserves

and 187 trillion cubic feet of proven natural gas. Also, there are opportunities for fertilizer and liquefied

gas production. With average production of about 2.3 million barrels of crude oil per day, Nigeria is the

largest exporter of crude oil in Africa and tenth largest in the world. The Nigerian economy is the largest

in West Africa and the second largest in sub-Saharan Africa, predominantly oriented toward the

production of agricultural products and crude oil. Agriculture accounts for about 30.9% of the GDP,

70.0% of employment but contributes only about 2.5% of export earnings. Crude oil and natural gas

account for about 15.0% of GDP, 71.0% of export earnings and 79.0% of government revenue.

2. 2 Nigeria Environmental Policies and Procedures

The goal of Nigeria’s national environmental policy is to achieve sustainable development based on

proper management of the environment. Primarily, the policy thrusts are to: secure a quality of

environment adequate for good health and well-being; conserve and use the environment and natural

resources for the benefit of present and future generations; restore, maintain and enhance the ecosystems

and ecological processes essential for the functioning of the biosphere to preserve biological diversity and

the principle of optimum sustainable yield in the use of living natural resources and ecosystems; raise

public awareness and promote understanding of the essential linkages between the environment, resources

and development, and encourage individual and community participation in environmental improvement

efforts; and co-operate in good faith with other countries, international organizations and agencies to

achieve optimal use of trans-boundary natural resources and effective prevention or abatement of trans-

boundary environmental degradation.

From ecological and economic standpoints, soil erosion is probably the most serious environmental

problem affecting the nation's soil and land resources. National policy objective is to evolve sound

planning and management of land resources in the country.

The National Energy Policy places emphasizes on the exploitation of Nigeria's renewable and alternative

energy sources - wind, solar and biomass, and provides guidelines for environmental protection in the

exploitation of Nigeria's fossil energy sources. It is yet to be enacted into law.

Environmental issue is administered by the Ministry of Environment at the Federal and States levels with

Environmental Health department at Local Government level. Established legislations relating to


environmental management include;

The Harmful Waste (Special Criminal Provisions) Act, 1988

The National Environmental Standards and Regulations Enforcement Agency Act 2007

(NESREA ACT, repealed the Federal Environmental Protection Act of 1988) - which is being

developed into the National Environmental Management Bill

Environmental Impact Assessment Act of 1992 - National Environmental Protection

(Management Procedure on Environmental Impact Assessment) Regulations (The principal

legislation which made EIA mandatory for both public and private sectors for all development

projects).

Environmental Impact Assessment (EIA) Act Cap E12,LFN 2004 (which sets out the general

principles, procedures and methods of Environmental Impact Assessment in various sectors)

Pest Control of Production (Special Powers) Act, CAP P9 LFN 2004

Agriculture Act and its Plant (Control of Importation) Act, CAP A93 LFN 2004

Sea Fisheries Act Cap. S$ LFN 2004

Endangered species Act Cap. E9 LFN 2004

Relevant regulations are

National Environmental (Sanitation and Wastes Control) Regulations, 2009)

THE National Environmental Protection (Pollution Abetment in Industries and Facilities

Generating Waste) Regulations

The Nigerian Constitution allows States to make legislations, laws and edicts on the Environment. The

ESIA Decree No. 86 of 1992 also recommends the setting up of State Environmental Protection Agencies

(SMENV), to participate in regulating the consequences of project development on the environment in

their area of jurisdiction. SMENVs thus have the responsibility for environmental protection at the state

level within their states. The functions of the SMENV s include:

Routine liaison and ensuring effective harmonization with the FMENV in order to achieve the

objectives of the National Policy on the Environment;

Co-operate with FMENV and other relevant National Directorates/Agencies in the promotion of

environmental education;

Be responsible for monitoring compliance with waste management standards;

Monitor the implementation of the ESIA and the Environmental Audit Report (EAR) guidelines

and procedures on all developments policies and projects within the State.

2.3 Agricultural Policies

The Nigerian Agriculture Policy revised in 2001 seeks to attain self-sustaining growth in all sub-sectors

of agriculture, a structural transformation of the overall socio-economic development of the country and

the improvement of livelihoods. Its strategies also aim at achieving self-sufficiency and improvement of

technical and economic efficiency in food production through the introduction and adoption of improved

technologies of production, efficient utilization of resources and the enhancement of producer capacities.

Its macroeconomic policies include appropriate pricing and trade, exchange rate stability and accessible

agricultural land. Sub-sector specific policies covered food production, input supply, subsidy

administration and support services

The policy defined complementary and synergistic roles for all the stakeholders made up of the three tiers

of government: Federal, States and Local Governments; and the private sector in line with the Nigerian


Constitution provision for facilitative and promotional roles to all the tiers of government in the exclusive

and concurrent legislative lists. It assigned roles to the 3-tiers of Government and Private Sector.

The Federal, state and local governments were required to differently and collectively work towards the

enthronement of a sound policy framework and strategies for reasonable flow of resources into

agricultural and rural development, support rural/agricultural infrastructure development, research and

development of appropriate technology for agriculture (including biotechnology) as well as promote

markets for products, inputs development, regulations and support agricultural service delivery. Others

are to manage Nigeria’s land and water resources, pests and diseases control and bilateral and multilateral

Agreements on Agricultural Trade reached between Nigeria and the World Trade Organization (WTO).

The states were to particularly promote the primary production of all commodities (including direct state-

funded production), extension services and ensure access to land, irrigation and appropriate farm

mechanization systems, etc. Others include credits provision to smallholder farmers, maintenance of

buffer stocks of agricultural commodities, rural development (roads and water supplies) and control of

forest resources. The local governments should provide effective agricultural extension service and

mobilize farmers, cooperative organizations and local institutions for higher production and enhance land

access.

The private sector role in entrepreneurship investments into all aspects of agricultural production and

value chains was maintained. It expects the sector to drive agricultural input chain as well as agricultural

mechanization getting involved in enterprise-specific rural infrastructure and support research in all

aspects of agriculture.

3.0 Potential Environmental Impacts and Recommended Determinations, Including Conditions Some potential environmental issues and impacts are likely with the implementation of activities of the

Development Objective Two provided in this section 1.3. The details of the general potential

environmental impacts of agricultural interventions including small scale irrigation are discussed in this

section. General impacts likely to result from construction activities are also outlined. The list of potential

impacts is indicative rather than exhaustive; these potential impacts are referenced at several points in the

analyses of the various activity categories.

3.1 Environmental impacts of agriculture competitiveness activities

Introduction of new/ improved varieties: There are many ways in which the introduction of

non-native or exotic species negatively affects our environment and the diversity of life. New

crop varieties may constitute a major threat to native biodiversity and they can change an entire

habitat, placing ecosystems at risk and often crowd out or replace native species that are

beneficial to a habitat.

Increased use of high levels of complementary Inputs: Increased production system involves

the inputs such as irrigation, chemical fertilizers and pesticides to achieve maximum yields; this

however, is often accompanied by negative environment impacts. The negative effects of

intensive farming include soil degradation, salinization of irrigated areas, over-extraction and

pollution of groundwater, resistance to pesticides, erosion of biodiversity, etc. Inappropriate use

of pesticides in particular presents profound risk to human and environmental health. While less

potentially harmful to human health, the misuse of fertilizers presents distinct risk to the natural


environment, with ground and surface water resources most vulnerable to ‘nutrient loading’

through over-application and poor management of agricultural run-off.

Disturbance of natural vegetative covering: This disturbance may lead to increased soil erosion

and vulnerability to landslides. As the soil erodes, less rainfall is absorbed and the excess runs

off. This runoff removes the fertile topsoil necessary for crop production and can have disastrous

off-site consequences, including gully formation, landslides, siltation and sedimentation of water

bodies, downstream flooding, and damage to productive infrastructure. In Northern Nigeria,

particularly in arid and semi-arid areas, the wind can also erode away the soil.

Contamination of water sources: Intensive farming has also the potential for the contamination

of water sources. Surface runoff carries manure, fertilizers, and pesticides into streams, lakes, and

reservoirs, in some cases causing unacceptable levels of bacteria, nutrients, or synthetic organic

compounds. Similarly, water percolating downward through farm fields carries with it dissolved

chemicals, which can include nitrate fertilizers and soluble pesticides, these can contaminate

groundwater supplies. In addition, pesticides impoverish the soil by increasing its toxicity so that

they destroy even more of the soil’s micro-organisms, which progressively results in the loss of

organic matter and soil erosion. Faced with this problem, the farmers add more fertilizer and

further exacerbate the situation or are force farmers to abandon fields.

Dams and irrigation schemes: Such schemes may present a number of distinct environmental

risks. Stagnant water behind dams can create breeding habit for disease vectors. Dams raise local

groundwater levels (which, while sometimes a desired objective, can lead to increased

contamination of groundwater). Excess withdrawals to serve the irrigation schemes can result in

insufficient water for downstream ecosystems and users. Poorly managed irrigation schemes can

result in permanent adverse effects to soil quality (e.g., salinization); they are also pose high risk

of contaminating shallow groundwater and downstream surface waters with agricultural

chemicals. Irrigation can affect downstream water quality by reducing the amount of water

available to dilute contaminants and by potentially increasing agrochemicals pollution.

Agricultural Processing: Such processing has significant potential environmental and health

impacts associated with their operation. In operation, these facilities generate significant

quantities of wastewater and organic wastes. If provisions for waste management are not part of

the facility design and/or if these wastes are improperly managed, these wastes can contaminate

water supplies and/or provide ready habitat for disease vectors such as flies, mosquitoes and rats.

The result is an increase in disease, particularly oral fecal route diseases.

3.2 Environmental impacts of small scale construction activities

Disturbance to existing landscape/habitat: Construction typically necessitates clearing,

grading, trenching and other activities that can result in near-complete disturbance to the pre-

existing landscape/habitat within the plot. If the plot contains or is adjacent to a permanent or

seasonal stream/water body, grading and leveling can disrupt local drainage.

Sedimentation/fouling of surface waters. Runoff from cleared ground or materials stockpiles

during construction can result in sedimentation/fouling of surface waters, particularly if the site is

located in close proximity to a stream or water body. Such risks are particularly acute in the case

of dam construction or rehabilitation where construction is within the stream or riverbed.

Stagnant water: Construction may result in standing water on-site, which readily becomes

breeding habitat for mosquitoes and other disease vectors; this is of particular concern as malaria

is endemic in Nigeria.

Adverse impacts of materials sourcing. Construction requires a set of materials often procured

locally: timber, fill, sand and gravel, bricks, etc. Unmanaged extraction of these materials can

have adverse effects on the environment. For example, stream bed mining of sand or gravel can

increase sedimentation and disturb sensitive ecosystems; purchase of timber from unmanaged or


illegal concessions helps drive deforestation. Similarly, the operation of constructed facilities has

a well-known set of potential adverse impacts.

3.3 Environmental impacts of aquaculture activities

Reference is made in the IEE to activities to promote livelihood and income generating opportunities

through small scale aquaculture. Aquaculture work could be complex, and must rely upon specific

expertise to ensure effective implementation. These activities will also require proper impact analysis and

planning to incorporate appropriate mitigation measures into activity implementation. Aquaculture in fish

ponds requires adequate site selection and design to prevent contamination of ground waters from

seepage, impacts to wild fish and aquatic organisms, damage to sensitive wetland ecosystems, and

introduction of invasive fish species that can displace wild fish populations and degrade aquatic habitats,

etc.

Additional operational mitigation measures that maintain ponds clean and suitable for fish production are

also required to control nutrient loading, find disposal and re-use strategies for fish wastes, control pests

and disease, maintain adequate water circulation and oxygen levels, to mention a few. None of these

design considerations (and their associated environmental impacts) are addressed in the IEE. Additional

information for impact and mitigation planning related to fisheries and aquaculture can be found at the

USAID’s Sector Environmental Guidelines (Agriculture, Construction, etc.

http://www.usaidgems.org/sectorGuidelines.htm).

3.4 Sub-grant Activities

Environmental Screening and Review for sub-grant activities (all activities involving sub grant

activities) for all program areas that are likely to have sub-grants to local Non-Governmental

Organizations (NGOs) and Community Based Organizations (CBOs)

Any grants or other fund transfers made by organizations receiving USAID funds to other organizations

(e.g., sub grants) to support this DO’s activities must incorporate provisions that the activities to be

undertaken will be within the envelope of the environmental determinations and recommendations of this

IEE. This includes assurance that the activities conducted via those transfers fit within the description of

activities described in an approved IEE or IEE amendment covering this DO, and that any mitigating

measures required for those activities will be followed.

The instructions and the form can be found, under “Subsidiary Review,” at the following web site:

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

3.5 Energy Access Activities (IR 2.2) & Energy Sector Enabling Environment

Given the fact that energy provision, with its associated infrastructure (e.g., generating equipment,

transmission lines, and construction), can be associated with potentially significant adverse environmental

and social impacts, appropriate due diligence measures need to be provided for. A system of standards,

environmental review -- and invoking host country and lender environmental and social soundness

policies and procedures -- needs to be reinforced by transaction advisors at all levels of negotiation and

transaction policy support. For “late-stage” investments, EAs and ESIAs should already have been

produced, and should be located and reviewed by USAID for “sufficiency.” For early-stage transactions,

and likely future projects, loan providers and recipients may not yet be fully apprised of their

responsibilities with regard to ensuring that ESIAs for these projects are produced and mitigation

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

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


measures are factored into the funding.

NOTE:

The BEO may determine that pertinent activities financed by USAID/Nigeria, GoN, or other lenders and

donors satisfy the environmental and social due diligence requirements.

The following sorts of illustrative actions and mitigation provisions should be factored into energy sector

development and integration dialogue and investments:

1. Environmental, health and safety management must be fully integrated into these activities; EG shall

submit for MEO review and approval IP’s plans for achieving such integration prior to implementation of

these activities.

2. Firms receiving substantial TA shall, as a condition of receiving this support, be in compliance with all

pertinent host country requirements, or commit to compliance as an outcome of this TA.

3. Firms being considered for substantial individual TA must first undergo an initial environmental,

health and safety (EHS) review of their operations for general soundness and compliance with host

country requirements. This assessment must be the basis for compliance commitments and supportive TA

as required above. Assessments must be updated following conclusion of assistance. All such assessments

must be maintained in project files and summaries in quarterly or 6-month project environmental

compliance reporting.

4. A strengths/gaps assessment must be conducted of: (1) Host country EHS regulation and performance

standards for enterprises and activities in the oil and gas sector supply chain; and (2) the capability of

cognizant government entities to enforce these requirements. A particular focus must be standards

involving transport, maintenance, waste management, and any direct support to production.

5. Based on these strengths/gaps assessment, USAID must engage in suitable regulatory and enforcement

capacity-strengthening activities with appropriate Government entities. While it is acknowledged that

final decisions regarding regulations, policies and enforcement strategy lie with the Government, USAID

TA must emphasize, wherever practicable, the following known elements of successful SME regulatory

approaches: (1) public reporting of firm performance; (2) simplification and accessibility of regulatory

language; (3) treatment of enforcement and education/outreach as necessary, complementary activities.

3.6 Financial intermediation, international finance institutions (IFI), loan guarantees,

Development Credit Authority (DCA) commitments.

When loan portfolios or direct loan guarantees, include potentially high-risk sectors such as mining,

power and associated infrastructure (e.g., transmission lines), and construction, these sectors are often

associated with potentially significant adverse environmental and social impacts. The investments could

likely fund a range of future projects and as these loan providers and recipients are not fully known at the

time of this review and, thus, EAs and ESIAs for these projects may be unavailable.

The Operating Unit shall ensure that the Guaranteed Party or Parties have environmental screening

system sufficient to demonstrate compliance with host government environmental laws and to enable

USAID to make an assessment of the environmental impact of such activities and shall submit to USAID

their proposed policies and procedures to assure that the projects financed are environmentally sound and

comply with applicable laws and procedures.


In the event a DCA or GDA is to be established, refer to guidance on the Global Environmental

Management Support (GEMS) website2, and consult with the respective PA Transaction Advisors,

Regional Environmental Advisors (REA) and Bureau Environmental Officer (BEO). Corporate

Environmental and Social Responsibility will be promoted.

A significant portion of Power Africa will be undertaking many activities upstream in the transaction

cycle: policy development, project feasibility, legal support, capacity building, financial intermediation,

etc., to address such projects in which the activities are just being defined. Clearly, at some point, an

environmental review or due diligence process would need to be followed when considering the

investments to be made with loans, and the like.

As Power Africa engages in new ways with MDBs & PIOs, private lenders, and many other partner

organizations, we will need to rely on their own respective due diligence procedures. A significant

portion of Power Africa will be undertaking many activities upstream in the transaction cycle: policy

development, project feasibility, legal support, capacity building, financial intermediation, etc., to address

such projects in which the activities are just being defined. Clearly, at some point, an environmental

review or due diligence process would need to be followed when considering the investments to be made

with loans, and the like.

USAID should seek to develop its guarantee deals with an "Equator Principles" Finance Institution, which

will have an Environmental and Social (E&S) Management System (ESMS) and an E&S due diligence

procedure, as well as E&S officers. An ESMS covers compliance, with an Exclusion list, national laws,

and performance standards. The Equator Principles for Environmental and Social Responsibility typically

only apply to the largest banks with large capitalization.

USAID/AFR’s BEO will establish a third Party Environmental Compliance Verification process for the

ESIAs produced to respond to host country requirements.

DCA agreements for Loan Portfolio Guarantees and for other guarantees where the purpose is

capitalization to facilitate direct on-lending should include the “model language” developed by USAID’s

Office of Development Credit. This language is reproduced in Annex 4. It is assumed that this language

is used for all LPG agreements and for other guarantee agreements used for capitalization to facilitate on-

lending.

The language provides for DCA credit guarantees/coverage to be withheld from environmentally “high

risk” activities (cases where Reg. 216 requires an EA and activities restricted by the FAA), except with

USAID prior review and approval. That is, if such a loan is made without first obtaining prior approval,

DCA provides no coverage in case of default.

What constitutes prior approval of loans for environmentally sensitive activities?

Individual loan approval: When the activity is configured so that USAID (or a USAID-funded

project) reviews and approves all loans, an Environmental Review Form (ERF) or similar process

must be completed for each loan in the portfolio. In this case, the approved ERF constitutes prior

approval, unless the ERF requires that an EA be conducted. (Note that environmental management

conditions specified in the ERF become loan conditions.)

Program approval: When the activity is NOT configured so that USAID (or a USAID-funded

project) reviews and approves all individual loans, AND host country environmental regulations and

2 http://www.usaidgems.org/Documents/complianceTopics/Cadmus_GDA_factsheet_19Dec06final_draft.doc

http://www.usaidgems.org/Documents/complianceTopics/Cadmus_GDA_factsheet_19Dec06final_draft.doc


regulatory capacity are adequate, prior approval is granted once the Contracting Officer’s

Representative (COR) (in collaboration with the MEO) approve the lender’s environmental due

diligence and management plan.

Hybrid approach: When the activity is NOT configured so that USAID (or a USAID-funded

project) reviews and approves all individual loans, BUT host country environmental regulations and

regulatory capacity are NOT adequate, then the IEE may require that USAID be notified and grant

specific prior approval for all loan applications involving environmentally sensitive activities.

In this case, the Guaranteed Party should submit to USAID documentation sufficient to demonstrate

compliance with local environmental laws and to enable USAID to make an assessment of the

environmental impact of the activities that will result from the loan. This will normally take the form of

an EA meeting host country or USAID requirements, whichever is more stringent. Compliance with

mitigation measures specified in this EA or other documentation must be written into the loan agreement.

3.6.1. General environmental due diligence principles for Power Africa

Here are some general environmental due diligence principles that we would like to see considered by

Power Africa stakeholders across the board, and these may or may not apply to these DCA LGs:

a. Appropriate PA Operating Units shall ensure that the Guaranteed Party or Parties have environmental

screening system sufficient to demonstrate compliance with host government environmental laws and to

enable USAID to make an assessment of the environmental impact of such activities and shall submit to

USAID their proposed policies and procedures to assure that the projects financed are environmentally

sound and comply with applicable laws and procedures.

b. TA must explicitly incorporate in investment analyses potential environmental impacts and liabilities

and the costs of compliance with host country environmental requirements.

c. TA must advocate for the inclusion of environmental requirements, as appropriate, in contracts and

contract models.

d. Policy, investment and regulatory TA must fully integrate and advance strong energy sector

environmental and social performance as a core value.

e. Significant TA tasks for developing, reviewing or reforming energy resources policy, energy sector

investment frameworks, and energy sector regulation must involve outlining potential environmental and

social issues and impacts.

See the DCA conditions in Table 1, Energy Access Activities (IR 2.2) and Enabling Environment

Activities – IR 2.3.

3.6.2. An Illustrative DCA Loan Guarantee to Standard Chartered Bank to Zenith Bank of Nigeria

As an illustrative case, USAID’s DCA office will provide a loan guarantee (LG) on a $95 M loan from

Standard Chartered Bank to Zenith Bank Nigeria. The proceeds of the loan will be used to support capital

expenditure needs of recently privatized generation and distribution companies in Nigeria. Partners are

GuarantCo, Zenith Bank and Standard Chartered Bank. Both Standard Charter Bank (SCB) and Zenith

Bank are guided by corporate Environmental Policies (see Annex 9). These are high-level statements

which do reflect solid commitment on the part of both banks to adhere to environmental and social


management systems (ESMS)(Zenith Bank) and global environmental management system (GEMS) and

environmental and social credit risk assessment processes (Standard Chartered). Both banks assure us

that they do environmental and social risk analysis for borrowers and take measures to "avoid, mitigate

and manage risks" identified, beginning at a very early stage of the credit evaluation.

This is certainly encouraging. If possible, it would further be of value if USAID transactions advisors and

environmental staff could receive, as a courtesy, the actual ESMS and GEMS policy documents

themselves. In due course, it might be a good learning experience for USAID to see how this process is

effectuated in practice (e.g., select visits as part of an affirmative dialogue?).

In discussions with the DCA staff, we mapped out "bright line" provisions that would make as plain as

possible what USAID would like to see achieved by way of environmental and social due diligence by the

parties to the guarantee agreement, as well as by the "end user" of the on-lending (loan recipient). Those

would be stipulated in appropriate fashion in the respective guarantee agreements and covenants, viz.:

1. Corporate Environmental and Social Responsibility. Both lenders will have in place and

follow their own corporate internal and external Environmental and Social Management Systems

and apply them to their lending practices and evaluations of borrowers, and will take measures to

avoid, mitigate and manage" environmental risks. How exactly, would need to be defined. See

Annex 9.

2. Liquid fuel exclusion. Given USG priorities on low-emissions development (LEDS), we

would expect the lender (SCB) of the Guaranteed funds to have a Representation Letter ("rep")

from Zenith as a covenant that the Guarantee would exclude support to power generation that

involve liquid fuels, esp. diesel, and would favor renewable energy investments (the latter point

may need to be discussed as to its "fit.")

3. Decommissioning and disposal of surplus assets. Given the situation in which privatized

assets will be upgraded, and some systems decommissioned, we would like to see some

provisions assuring that waste generated from transmission system renovation (e.g., old

transformer PCBs disposal) would be appropriately disposed of (how exactly -- to be stipulated

later?). Regarding decommissioning and specifically the management of PCBs, it is agreed that

appropriate handling is important and preferable. However, given the relationship wherein DCA

is three steps removed from the "end user" of the loans, it is difficult to determine how this would

be directed, monitored, and resourced. This is where we will need to rely on Nigerian host

country oversight and compliance with national regulations.

4. End user responsibility. The "end user" of the on-lending (loan recipient) (two steps removed

from the Guarantee) will be expected by Zenith to comply with local laws, regarding any ESIAs,

permits, and the like, that may be needed. A system of verification should be worked out.

5. Deal-specific IEE. Consider appropriateness and value added of a "Deal-specific" IEE for

such capital expenditure mobilization investments.

4.0 Recommended Threshold Decisions & Mitigation Actions (Including Monitoring and Evaluation)

Categorical Exclusion in pursuant to 22 CFR 216.2(c)(2) is recommended for the following activities in

support of agricultural competitiveness: improved energy access and improved enabling environment.


These activities will not have adverse effects on the environment as detailed in Table 1.

(i) Activities involving education, training, technical assistance or training programs except to the

extent such programs include activities directly affecting the environment (such as construction of

facilities, etc.);

(ii) Activities involving controlled experimentation exclusively for the purpose of research and field

evaluation and carefully monitored;

(iii) Activities involving analyses, studies, academic or research workshops and meetings;

(v) Activities involving document and information transfers;

(viii) Programs involving nutrition, health care, or family planning services except to the extent designed

to include activities directly affecting the environment (such as construction of facilities, water

supply systems, waste water treatment, etc.); .

Negative Determinations with conditions are recommended for the following activities: Per 22 CFR 216.3 (a) (2) (iii):

Strengthen the capacity of local agro-business organizations to improve distribution

Formation of major seed and fertilizer alliances to increase supply of inputs

Promote use and adoption of available improved seed/varieties, and sustainable water/soil

management and post-harvest technologies

All pesticide-related activities referenced in MARKETS II PERSUAP, which will govern all

pesticide use and capacity building

Commercialization and Post-Harvest Activities (food processing)

Construction of water catchments and small scale irrigation technologies to provide irrigation and

potable water

Small scale construction of food storage warehouses and cold storage facilities

Aquaculture

Provision of agricultural credit guarantees via NIRSAL

T.A. to DCA-supported SME loan facility for agricultural value chain development

Technical assistance to Power Africa-related DCA loan portfolio guarantee (LPG), portable

guarantee (PG) or loan guarantee agreements between international and local commercial bank(s)

to support, e.g., (a) capital expenditure needs of recently privatized generation and distribution

companies in Nigeria, (b) financial risk mitigation in loaning to a solar leasing company (Amp

Ventures) seeking to deploy throughout Nigeria, and (c) others to be determined.

T.A. for GDA through PFAN

Sub-grant Activities (Project Development Facility, Catalytic and Innovation Funds)

Table 1: Summary of the Recommended Determination and Conditions

Illustrative Activities Recommended Determinations

Agricultural Competitiveness Activities – IR 2.1

Strengthening the capacity of local

agro-business organizations to

improve private sector distribution

of inputs.

Formation of major seed and fertilizer

alliances (to increase the supply of

quality seed, fertilizer, and other inputs

to millions of small-holder farmers and

stimulate productivity increases.)

Negative determination pursuant to 22CFR216.3(a)(2)(iii) is

recommended subject to the conditions that: (1) training for technical

support providers must adequately address appropriate measures of

handling of equipment and fertilizers use of must conform to best

practices outlined in the Africa Bureau Fertilizer Fact Sheet(see Annex

3); and (2) all activities will conform to the relevant

aspects and provisions of the MARKETS II or other relevant

PERSUAPs.



Enhance the capacities of small and

medium agro-enterprises, producer

organizations/associations, (male and

female) through training to increase

businesses and entrepreneurial

skill, contract negotiations, product

management, and organizational

governance.

Categorical exclusion is recommended pursuant to

22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)

Promote use and adoption of

available improved seed/varieties of

target crops; sustainable soil and

water management practices (e.g.

drip irrigation, improved fallows,

and inorganic and organic fertilizer

application, integrated pest

management techniques, small

irrigation technologies and

management); and potentially

profitable post-harvest technologies.

Negative determination pursuant to 22 CFR 216.3(a)(2)(iii) is

recommended subject to the conditions that: (1) training for technical

support providers must adequately address appropriate measures of

handling of equipment and fertilizers use; (2) fertilizers be thoughtfully

employed according to best practice, promoting integrated soil fertility

management, within the context of the prevailing biophysical and socio-

economic conditions, as well as the desired outcomes. These must

conform to best practices outlined in the Africa Bureau Fertilizer Fact

Sheet (Annex 3); (3) all activities will conform to the relevant aspects

and provisions of the MARKETS II or other relevant PERSUAPs; (4)

good-practice design and operation standards must be implemented,

generally consistent with good-practice guidance of USAID’s Sector

Environmental Guidelines (Agriculture, Construction;

http://www.usaidgems.org/sectorGuidelines.htm); (5) introduce only

properly tested equipment and varieties approved by Government of

Nigeria. Existing Nigerian laws, regulations and policies be ascertained

and followed prior to dissemination of technologies; and (6) precautions

are taken to prevent dissemination of stress, disease or insect resistant

varieties outside the agro-climatic zones and agricultural technologies for

planting are not damaging to the environment and do not lead to soil

erosion and/or degradation.

Support activities addressing

warehouse receipt, agricultural

commodity trading and accessible

market information systems; meeting

market standards.

Negative determination per 22 CFR 216.3(a)(2)(iii) with conditions

that:

1) For activities related to enhancing market development systems, a

requirement will be to conduct internal analysis/review of potential

environmental impacts from increased production, harvesting and/or

value-added processing for proposed new product/market linkages (see

the GEMS Food Processing Cleaner Production Factsheet at

http://www.usaidgems.org/mse/foodProcessing.htm). TA will conform to

relevant aspects and provisions of the MARKETS II PERSUAP.

Support activities addressing public

and private investments that advance

agricultural value chain and efficient

agricultural marketing such as

storage facilities, cold storage,

packaging facilities, and agricultural

processing facilities.

Negative determination per 22 CFR 216.3(a)(2)(iii) with conditions

that:

1) Precautions are taken to prevent environmental damage from improper

waste management and disposal by conducting training and information

dissemination on proper management and disposal of wastes. 2) Any

small-scale construction shall be conducted in a manner consistent with

best practices as outlined in the Small Scale Construction chapter of the

USAID Sector Environmental Guidelines.

(http://www.usaidgems.org/sectorGuidelines.htm); and,

2) An environmental management course entitled “Improving Micro- and

Small Enterprise Success through Cleaner Production” is recommended

for Objective Development partners (www.encapafrica.org/sme.htm).

This provides an opportunity to provide leadership and innovation in





environmental capacity-building for business service organizations that

assist SMEs.

3) Business development services for enterprises and cooperatives; and

pilots and demonstrations will (1) incorporate and promote sound

environmental management practices (see GEMS Food Processing

Cleaner Production Factsheet

http://www.usaidgems.org/mse/foodProcessing.htm); (2) convey--and, in

the case of demonstrations and pilots, comply with--Malawian

environmental and public health requirements pertaining to these

operations; and (3) conform to relevant aspects and provisions of the

2012 SEG PERSUAP.

Support the transfer and adaptation of

proven technologies and human

organization innovations to increase

market access, food or cash transfers in

exchange for public works; and

resource transfers and/or agricultural

inputs (e.g. seeds, tools, and livestock)

which enable male and female

producers to try new technologies

and production methods that would

otherwise not be available to them.


22CFR216.2(c)(2)(iii),

Conduct value chain analysis of

major targeted commodities such as

rice, maize, cassava, soybean,

sorghum and aquaculture.

Negative determination pursuant to 22CFR216.3 (a)(2)(iii) is

recommended subject to the condition that:

If aquaculture is to be promoted by EGE partners, the EMMP

must include detailed analysis of potential impacts and

mitigation measures to deal with likely impacts at program sites

and must be generally consistent with good-practice guidance of

USAID’s Sector Environmental Guidelines (Agriculture,

Construction; http://www.usaidgems.org/sectorGuidelines.htm).

Expanding new multi-partner value

chain alliances; and increasing business

capacity of agricultural firms.


22CFR216.2(c)(1)(i).

Construction of water catchments

and small scale irrigation

technologies to provide irrigation

and potable water and encourage

farmers to rear small stock that require

less feed and support agro-processors

water supply need within targeted

commodity value chains.


recommended

subject to the following conditions:

1. Construction of Small Scale Irrigation (<50 Ha irrigated area):

a) The formal AFR subproject/sub grant review process, as set out by the

AFR Environmental Review Form (available at

http://www.usaidgems.org/compliance.htm) must be completed and

approved prior to construction of each site/system. The ERF must

specifically address the potential impacts identifies in the above analysis

of this activity

b) The environmental management conditions established by the ERF

process must be generally consistent with good-practice guidance of

USAID’s Sector Environmental Guidelines (Agriculture and Irrigation,

Construction; http://www.usaidgems.org/sectorGuidelines.htm).

c) The IP must assure implementation of any mitigation and monitoring

conditions specified by the approved ERF.

d) Complementary support to a user’s association or other management

entity must be provided or suitable capacity for managing the scheme

otherwise assured.

2. Construction of Water Catchments for Potable Water:





For water supply activities, the IP will develop and implement a Water

Quality Assurance Plan that will ensure that all new and rehabilitated

USAID-funded water supplies provide safe drinking water, defined as

meeting local and WHO water quality standards.

This Plan must be approved by the MEO prior to initiation of

these activities.

The plan must include and assign responsibility to the IP for

initial water quality testing. When feasible, the program must

also set in place capacities and responsibilities to provide

reasonable assurance that ongoing water quality monitoring

occurs.

The standards for initial and ongoing testing— including types

of contaminants for which testing should be conducted, testing

methods, testing frequency, and issues such as public access to

results— should follow any applicable USAID guidance, as well

as local laws, regulations and policies.

The plan must include a response protocol in the event that the

water does not meet water quality standards.

The plan must include testing for Arsenic per Guidance Cable

State 98 108651 (if groundwater source) and fecal coliform.

Water violating the 10ppb Arsenic standard (if groundwater

source) or having detectable coliforms in any 100ml sample.

may not be supplied for public consumption.

At minimum, fecal coliform must be tested concurrently with

Arsenic (if groundwater source).

Support marketing campaigns to

improve the visibility and raise

awareness of Nigeria’s products and

branding. Production of marketing

materials and educational guides

needed to raise awareness and

understanding of market information

systems.


22CFR216.2(c)(1)(i),

22CFR216.2(c)(2)(iii)

Support nutrition education and

awareness, introduction of more

nutritious and fortified foods.

Collaboration with the HIV/AIDS and

Tuberculosis Office on the procurement

and distribution of fortified foods.


22CFR216.2(c)(1)(i),

22CFR216.2(c)(2)(iii); 22CFR216.2(c)(1)(viii)

Promotion of the production and

utilization of cowpeas, shea nuts,

poultry, small ruminants, vegetables

or other nutritionally important and

/or marketable products that do not

require large land areas and are often

classified as poor people’s or women’s

activities


recommended

subject to the conditions that:

1) Sustainable practices are promoted through the identification and

promotion of the value chains.

2) Introduce only properly tested equipment and varieties approved by

Government of Nigeria.

3) Existing Nigerian laws, regulations and policies be ascertained and

followed prior to dissemination of technologies.

4) Precautions are taken to prevent dissemination of stress, disease or

insect resistant varieties outside the agro-climatic zones and agricultural

technologies for planting are not damaging to the environment and do not

lead to soil erosion and/or degradation.

Conduct performance and impact Categorical exclusion is recommended pursuant to



evaluations of targeted value chain

interventions and studies on diversified

economic opportunities to demonstrate

innovations and technologies that

reduce women’s labor burden and/or

increase productivity of labor

22CFR216.2(c)(2)(iii)

Administer grant funds: (a)

Innovation Fund to promote

innovative applications (ideas,

processes, equipment, training, designs)

that can be introduced into the

commodity value chain to enhance

productivity, increase efficiency,

improve a process or otherwise lead to

some practical benefit to producers or

to agri-businesses;

(b) Project Development Facility

Fund to provide technical assistance to

enterprises in creating a bankable

export business plan, market

assessments, bringing products up to

international standards, packaging and

labeling requirements, food testing

certification, SPS standards,

transportation, marketing and sales.

Negative Determination with Conditions is recommended for all sub-

grant activities likely that have a direct effect on the environment.

1) Any grants or other fund transfers made by organizations receiving

USAID funds to other organizations (e.g., sub grants) to support this

DO’s activities must incorporate provisions that the activities to be

undertaken will be within the envelope of the environmental

determinations and recommendations of this IEE.

2) This includes assurance that the activities conducted via those

transfers fit within the description of activities described in an approved

IEE or IEE amendment covering this DO, and that any mitigating

measures required for those activities will be followed.

The instructions and the Environmental Review Form can be found,

under “Subsidiary Review,” at the following web site:

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

Suggested language to promote environmental compliance in

solicitations and awards can be found in the ADS 204 help document,

“Environmental Compliance: Language for Use in Solicitations and

Awards.” (http://www.usaid.gov/policy/ads/200/204sac.pdf). Sound sectoral guidance can be found in USAID Africa Bureau's

Environmental Guidelines for Small-Scale Activities in Africa: Use of

Environmental Screening form as apt:

http://www.encapafrica.org/compliance.htm.

Develop small-scale storage sheds to

store crops and other commodities

for later sale or for use as collateral

towards credit or insurance

Support food Processing and

packaging to significantly reduce in

current wastage and ensure extended

access

Support investment in water

supplies for food processing and

hygiene


recommended subject to the following conditions

1. Construction management:

The construction/rehabilitation must be consistent with construction

management requirements:

(a) During construction, prevent sediment-heavy run-off from cleared site

or material stockpiles to any surface waters or fields with berms, by

covering sand/dirt piles, or by choice of location.

(Only applies if construction occurs during rainy season.);

(b) Construction must be managed so that no standing water on the

site persists more than 4 days;

(c) IPs must require their general contractor to certify that it is not

extracting fill, sand or gravel from waterways or ecologically sensitive

areas, nor is it knowingly purchasing these materials from vendors who

do so;

(d) IPs must identify and implement any feasible measures to increase the

probability that timber is procured from legal, well-managed sources.

2. Water Supplies:

The well construction should follow good design and implementation

practices (Annex 7). Consultation should be carried out with all adjacent

well owners and operators and host country authority and agreement


http://www.usaid.gov/policy/ads/200/204sac.pdf

http://www.encapafrica.org/compliance.htm



reached on the location of the borehole to eliminate any potential

conflicts over water supply and withdrawals.

All wells should be securely sealed to ensure that no

microbiological contamination of ground water supplies occurs.

All wells should be constructed to ensure that no permanent

unmanaged standing water remains near the water supply area in

order to avoid the proliferation of water borne disease vectors

For water supply activities, the IP will develop and implement a

Water Quality Assurance Plan that will ensure that all new and

rehabilitated USAID-funded water supplies provide safe drinking

water, defined as meeting local and WHO water quality standards.

o This Plan must be approved by the MEO prior to initiation of

these activities.

o The plan must include and assign responsibility to the IP for

initial water quality testing. When feasible, the program must

also set in place capacities and responsibilities to provide

reasonable assurance that ongoing water quality monitoring

occurs.

o The standards for initial and ongoing testing— including types

of contaminants for which testing should be conducted, testing

methods, testing frequency, and issues such as public access to

results— should follow any applicable USAID guidance, as well

as local laws, regulations and policies.

o The plan must include a response protocol in the event that the

water does not meet water quality standards.

o The plan must include testing for Arsenic per Guidance Cable

State 98 108651 and fecal coliform. Water violating the 10 ppb

Arsenic standard or having detectable coliforms in any 100 ml

sample may not be supplied for public consumption.

o At minimum, fecal coliform must be tested concurrently with

Arsenic.

Procurement, use, promotion of, or

training in use of pesticides,

including herbicides, and fungicides.

Negative determination with conditions is recommended per

22CFR216.3(a)(2)(iii) for all continuing activities referenced in the

“Pesticide Evaluation and Safer Use Action Plan: Maximizing

Agricultural Revenue and Key Enterprises in Targeted sites II (Nigeria

MARKETSII PERSUAP_2013_2017)” approved 07/26/2013 (see link

on Face sheet) The condition is that the limitations and requirements

given in that assessment must be followed, and only those pesticides

identified and assessed in that PERSUAP may be used unless and until

that assessment is amended to include other products, and until that

amendment is approved by the Bureau Environmental Officer (BEO);

b. A deferral of a threshold determination, per 22 CFR

216.3(a)(7)(iii), is recommended for all pesticide-related activities NOT

referenced in the above PERSUAP. No pesticide import, distribution or

use is authorized for such activities unless and until a PERSUAP is

prepared in accordance with AFR Bureau guidance, fulfilling all

analytical elements required by 22CFR216.3(b), USAID’s Pesticide

Procedures, and until said assessment is approved by the BEO.

Activities involving the field testing

or open release of genetically

modified organisms (GMOs)

A deferral of a threshold determination, per 22 CFR 216.3(a)(7)(iii), is

recommended for the field testing or other release of genetically-

engineered plants, pending biosafety assessment of such testing and/or

release. Such field testing or other release cannot occur until USAID’s



Biosafety Procedures in ADS 201 are completed with respect to the

particular uses intended, and until an IEE or amendment is completed for

those uses, reflecting the findings in the biosafety review. As noted in the

attached summary of those procedures, the grantee/contractor or host

country collaborator must submit to the USAID A/COR or DO Team a

letter or letters from the relevant authority in the host country approving

the transfer, testing and/or release of the GE product, including any

specific conditions imposed by the host country. USAID will not grant

approval of the transfer, testing or release in the absence of this letter or

letters of approval.

Once the USAID Biosafety Officer confirms that the biosafety

procedures have been completed for the intended actions involving GE

products, this IEE should be amended or separate IEE be put in place to

reflect the appropriate threshold decision for the GE product-related

activity(ies).

Energy Access Activities – IR 2.2

Assist in privatizing existing state

energy companies, developing the

frameworks and promoting projects for

private investment in energy resources

exploration and production, processing

and conversion, transmission and

transportation, and distribution and

delivery of energy to end-users


22CFR216.2(c)(1)(i),

22CFR216.2(c)(2)(iii);

If “promotion of projects” includes financial intermediation, then

Negative Determination with conditions will apply:

1) IPs shall ensure that the Guaranteed Party or Parties have

environmental screening systems sufficient to demonstrate compliance

with host government environmental laws and to enable USAID to make

an assessment of the environmental impact of such activities and shall

submit to USAID their proposed policies and procedures to assure that

the projects financed are environmentally sound and comply with

applicable laws and procedures.

2) In the event a DCA or GDA is to be established, refer to guidance on

the GEMS website,

http://www.usaidgems.org/complianceTopics.htm, and consult with the

MEOs, REAs and BEO, as appropriate.

Build the capacity of the electricity

regulator to work with the private

sector to end gas flares in the Niger

Delta through the GON Accelerated

Gas Development Project (AGDP).


22CFR216.2(c)(1)(i),

22CFR216.2(c)(2)(iii);

DCA loan guarantees and T.A.

Nigeria Promoting Renewable

Energy and Energy Efficiency

Project.

Component 1: DCA instrument to

provide partial credit guarantees to

local Banks (initially Eco Bank and

First Bank) in order to increase debt

financing to the clean energy sector.

Component 3: T.A. for the successful

implementation of the Energy sector

activities. .

A Negative Determination with Conditions is recommended pursuant

to 22 CFR 216.3(a)(2)(iii) for this DCA loan guarantee intended to

strengthen the Guaranteed Party’s ability to finance loans to increase

access to finance for energy sector investments, associated infrastructure

construction and equipment, subject to the conditions that:

a) Guarantee Agreement with appropriate environmental due

diligence provisions. If the DCA Issuance team and the lenders are

favorable to the principle, appropriate environmental due diligence

provisions could be incorporated into the DCA guarantee

agreement. That would give USAID a sense that sound

environmental practices will be promoted and encouraged. In the

case of the construction of a power facility, for example, subject to

negotiation with the host government (and only for technical

assistance, collaborative, information and advisory purposes), a



The technical assistance component of

the Renewable Energy Project under

the LWA will develop (i) capacity of

financial institutions, particularly the

DCA banks, to ensure optimal

utilization of the DCA guarantee; (ii)

capacity of companies in the clean

energy sector and those in selected

sectors seeking to utilize renewable

energy, to provide a pipeline of

potential deals for the DCA banks; (iii)

capacity of government institutions to

encourage the enactment and

implementation of appropriate

legislation to incentivize private sector

participation in the development of the

clean energy market, and (iv) capacity

of vocational training institutes, to

strengthen the cadre of non-qualified

and qualified professionals to install,

operate, and maintain decentralized

renewable energy investments.

regime of environmental covenants could be incorporated into the

guarantee agreement that would require.

b) The Guaranteed Party shall provide for review by

USAID/Nigeria’s Mission Environmental Officer (MEO) and the

Regional Environmental Advisor (REA) a copy of its

environmental policies and procedures as a condition precedent to

this Guarantee Agreement.

c) The Guaranteed Party shall seek prior USAID approval and submit

evidence of environmental compliance before placing certain types

of loans under Guarantee coverage, to be specified appropriate

Guarantee Agreements with the involved bank(s).

d) The USAID/Nigeria Economic Growth Team will periodically

review the Guaranteed Party’s implementation of this requirement,

including during project monitoring visits.

e) Environmental compliance will comprise one of the performance

measures of the project’s mid and/or end-term technical evaluation

to be carried out by the USAID/Nigeria Economic Growth Team.

f) Small and Medium Size Enterprises accessing finance for energy

sector investments, associated infrastructure construction and

equipment, and the lending institution (i.e. the Guaranteed Party)

shall receive training and technical assistance in the use of

environment guidelines. The guidelines shall illustrate how

environmentally sound practices can be used to improve the

effectiveness and efficiency of the enterprise. Training of the

lending institution will include the concept of environmental due

diligence, awareness of the environmental hazards presented by

typical types of enterprises, and basic environmental management

appropriate to typical Small and Medium Size Enterprise activities.

Where technical assistance to the lending institution includes loan-

making procedures, basic environmental review will be built into

loan-making processes. This training and technical assistance will

support compliance with Nigerian law and implementation of good

practice as set out in this IEE.

g) Training with the partner banks on environmental compliance and

best practices: T.A. will be provided to the bank and loan managers,

risk assessment and due diligence officers to develop environmental

controls and checklists and train them on how to use these

checklists effectively as part of the loan process.

h) Mandatory reference: The USAID Sector Environmental

Guidelines --(http://www.usaidgems.org/sectorGuidelines.htm) --

and the Environmental Guidelines for Small Scale Activities in

Africa (www.encapafrica.org/egssaa.htm), specifically Section III

on Micro and Small Enterprises,

(http://www.encapafrica.org/egssaa.htm#III) , must inform

compliance with these conditions.

The following additional conditions are recommended when appropriate,

and are recommended as matter of policy when the parties to the DCA

guarantee agreement negotiate appropriate provisions. The Mission staff

managing the DCAs and the T.A. partner assisting with use of the DCA

will work with the banks to institute appropriate environmental controls

and the Mission is planning to do some training with the lenders and

borrowers that will facilitate the process.


http://www.encapafrica.org/egssaa.htm#III



i) The Guaranteed Party shall develop and provide for review and

approval by the USAID’s MEO and REA, a Compliance Plan

documenting how their project will implement and verify all IEE

conditions that apply to their activities. The Compliance Plan shall

identify how the Guaranteed Party shall assure that IEE conditions

that apply to activities supported under the loans are implemented.

j) The Guaranteed Party shall integrate their Compliance Plan into their

projects’ work plans and budgets, implement the Compliance Plan,

and report on its implementation as an element of regular project

performance reporting. The Guaranteed Party shall assure, through

training as described above, as well as the Compliance Plan that loan

recipients integrate implementation of IEE conditions, where

applicable, into their own project work plans and budgets and report

on their implementation as an element of loan performance reporting.

Nigeria Promoting Renewable

Energy and Energy Efficiency

Project.

Component 2: GDA with the Private

Financing Advisory Network

(PFAN), which will link

investors/financiers and clean energy

project developers to help produce

‘’bankable’’ project and equity

financing proposals.

A Negative Determination with Conditions is recommended

pursuant to 22 CFR 216.3(a)(2)(iii).

In the event a GDA is to be established, refer to guidance on the GEMS

website,



USAID funding will be provided only during the “pre-investment

phases” and will not provide for the follow-up engineering, construction

of production phases. ” However, since USAID investments will

introduce technologies and materials that are key to future commercial

operations, the pre-investment phase is pivotal to the conduct of the

remaining phases. As such, mitigation measures aimed at monitoring

and minimizing any potential negative impacts are included in the GDA

to assure that activities in which USAID is involved are environmentally

sound. Mitigation measures should be listed in the GDA agreement.

Participate in power generation

while also building the capacity of

the electricity regulator to effectively

regulate and incentivize the private

sector participation in the power

sector.


22CFR216.2(c)(1)(i),

22CFR216.2(c)(2)(iii) for capacity building activities.

If “participation in power generation ” includes support of actual

construction then Positive Determination will apply, per USAID’s 22

CFR Part 216.6 on Environmental Assessments:

1) Direct or indirect support to actual construction of power-related

infrastructure may require an Environmental Assessment, or certification

by USAID that an appropriate EA has been prepared.

2) Private sector investors in PPPs investing in major infrastructure will

likely need to support the preparation of appropriate host-country specific

Environmental and Social Impact Assessment documentation.

Enabling Environment Activities – IR 2.3

Conduct a climate change vulnerability

assessment to identify gaps and key

areas for Mission cross cutting

intervention in adaptation


22CFR216.2(c)(1)(iii);

22CFR216.2(c)(1)( v)

Warning System Network

(FEWSNET), an early warning system

that monitors food security, rainfall,

production and postharvest losses in


22CFR216.2(c)(1)(iii);

22CFR216.2(c)(1)( v)

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



order to prepare for disaster and

anticipate the amount of food aid

needed in case of drought.

Support the GON’s Agriculture

Transformation Agenda (ATA)

through investment prioritization and

the preparation of state agricultural

investment plans; conducting research

and analysis in key policy areas

including input availability, land

governance, water resources and

irrigation; and improving knowledge

management and analyses for

agricultural planning.


22CFR216.2(c)(1)(i),

22CFR216.2(c)(2)(iii); 22CFR216.2(c)(1)(v)

Support public education on key

agricultural policies and progress

toward developing and implementing

them. Use of media in creating

awareness amongst all stakeholders

regarding the policy process and the

implementation of policies key to the

economic and social resilience.

Creation of appropriate mechanisms

and opportunities for vulnerable

populations to engage in policy

dialogue.


22CFR216.2(c)(1)(i),

22CFR216.2(c)(2)(iii); 22CFR216.2(c)(1)(v)

Support the development of specific

guidelines and regulations that ensure

biotechnology laws are functional;

support the National Biosafety

Management Authority (NBMA) to

conduct evidence-based reviews for

decision-making; and developing and

implementing a strategy for bio-safety

outreach and communication.



Building government capacity to

develop agricultural statistics and

information systems; introducing best

practices to improve commodity

storage and handling to reduce post-

harvest losses; and providing technical

assistance to develop a food safety

policy.



Build public and private sector capacity

to analyze the impact of trade and

investment agreements on economic

growth, productivity, employment,

poverty, gender equity, fiscal revenues,

and other national and individual male

and female stakeholders’ interests.



Support institutions, policies and

incentives aimed at ensuring that

adequate, safe, and nutritious food is


22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v);

22CFR216.2(c)(1)(viii)



available; markets function efficiently;

and that low-income groups and those

vulnerable to food insecurity (e.g.,

female farmers with small land

holdings, female-headed households,

children, and HIV-affected) are able to

access and appropriately utilize that

food.

Support trade liberalization. Build the

capacity of the public sector to meet

requirements for accession to the WTO

and participating effectively in the

WTO system and to meet other

international agreements such as the

U.S. Free Trade Area agreements and

Bilateral Investment Treaties.



Provide technical assistance in

developing implementing regulations

and policies for the new CEMA and

capacity building and training for the

Nigerian Custom Service (NCS) to

improve its ability to oversee the new

regulatory framework. Provide training

in valuation and the use of tools such as

scanners to help NCS attain its goal of

internalizing destination inspection

services.

Provide training on benchmarking

effectiveness of trade facilitation

metrics and the implications of these

for customs modernization.



Support Corridor Management

Group (CMG) to improve

coordination along the Lagos—

Kano—Jibya transportation corridor

connecting the port of Lagos with the

inland countries of Chad, Niger and

Burkina Faso.


22CFR216.2(c)(1)(i); 22CFR216.2(c)(1)(iii) for pure capacity building,

T.A., etc.;

If “support” includes financial intermediation, then Negative

Determination with conditions will apply:









the GEMS website,



If “support ” includes support of actual construction then a Positive




Determination could apply:

1) Direct or indirect support to actual construction of transportation-

related infrastructure may require an Environmental Assessment, or

certification by USAID that an appropriate EA has been prepared.

2) Private sector investors investing in major infrastructure will likely

need to support the preparation of appropriate host-country specific

Environmental and Social Impact Assessment documentation.

Provide technical assistance and

training to policy makers in the power

and oil and gas sector, embedding an

advisor into the Nigerian Bulk

Electricity Trading Company to

improve its capacity to negotiate, and

procure competitive electricity.



Create a renewable energy regulatory

framework, a cost reflective tariff; and

improve the regulatory environment for

private sector investments.



Support GON efforts to improve the

policy and regulatory environment for

clean energy production; reduce gas

flaring and make captured gas available

for the generation of clean energy;



Provide technical assistance to the

GON on voltage management and

liberalization of the power sector.

For technical assistance on voltage management, Categorical exclusion

is recommended pursuant to 22CFR216.2(c)(1)(i);

22CFR216.2(c)(1)(iii); 22CFR216.2(c)(1)( v)

If “liberalization” includes financial intermediation, then Negative

Determination with conditions will apply:









the GEMS website, http://www.usaidgems.org/complianceTopics.htm,

and consult with the MEOs, REAs and BEO, as appropriate.

Provision of Agriculture credit

guarantees by working with the

Nigeria Incentive-Based Risk-Sharing

System for Agricultural Lending

(NIRSAL).

Negative Determination with conditions:









the GEMS website,







Support public education on key

policies and progress toward

developing and implementing them.

Use of media in creating awareness

amongst all stakeholders regarding the

policy process and the implementation

of policies key to the economic and

social resilience. Creation of

appropriate mechanisms and

opportunities for vulnerable

populations to engage in policy

dialogue.

Categorical exclusion is recommended pursuant to 22CFR216.2(c)(1)(i)

22CFR216.2(c)(2)(i), 22CFR216.2(c)(2)(v)

Provide technical assistance to

financial institutions who house the

DCA guarantee for investment in

small and medium renewable and

energy efficient companies; agro

processing, and warehousing

companies, and public and private

facilities willing to retrofit facilities

with clean energy.

This is consistent with the USAID

Nigeria Renewable Energy DCA IEE.

See Facesheet for link.

Negative Determination is recommended pursuant to 22 CFR

216.3(a)(2)(iii) for this DCA loan guarantee to Bank loans to increase

access to finance for the renewable energy, energy efficiency and

agribusiness Small and Medium Enterprises (SMEs) in Nigeria subject to

the conditions that:

The EGE team with support of the MEO shall ensure that the Guaranteed

Parties have environmental screening system sufficient to demonstrate

compliance with Nigeria Environmental Impact Assessment (EIA) Act.

Cap E12, LFN 2004 and to enable USAID to make an assessment of the

environmental impact of such activities and shall submit to USAID their

policies and procedures to assure that the projects financed are

environmentally sound and comply with applicable laws and procedures.

The Guaranteed Parties shall seek prior USAID approval and submit

evidence of environmental compliance before placing certain types of

loans under Guarantee coverage as specified in the Development

Guarantee Agreement annexed to this IEE. (Annex 4)

As a matter of desirable policy, if the DCA Issuance team is favorable to

the principle, appropriate environmental due diligence provisions can be

incorporated into the DCA guarantee agreement, that would give USAID

a sense that sound environmental practices will be promoted and

encouraged. In the case of the construction of a power facility, for

example, subject to negotiation with the host government (and only for

technical assistance, collaborative, information and advisory purposes), a

regime of environmental covenants could be incorporated into the

guarantee agreement that would require:

1. The current model agreement language on the types of activities which

are prohibited under 22 CFR 216 (see Annex 4 in the present IEE).

2. Adherence to the government’s and company’s own environmental

policies and action plan;

3. The right of USAID environmental officers to review the GoNs

solicitation for contractors and to offer comments to the environmental

provisions of such solicitation;

4. A similar right to review the environmental provisions of the contract

awarded to construct the marketplace;

5. The right to receive reports that are already required either under the

local government’s action plan, or under the construction contract; and

6. The right to access the project site at the same times as the project



engineer would perform site visits.

In the case of Nigeria, three Ecobank files have been received from the

USAID Nigeria Mission to demonstrate the due diligence in place for the

Ecobank Agreement: a) the Guarantee Agreement, b) transaction report

summary, and c) Ecobank's Env & Social Assessment Polices &

Procedures.

5.0 Restrictions, Implementation and Monitoring

5.1 General Restrictions:

GMOs/LMOs: For purposes of compliance with USAID procedures, Genetically Modified

Organisms (GMOs) or Living Modified Organisms (LMOs) are defined as “living organisms

modified by genetic engineering techniques” and include, e.g., plants, microorganisms, live

animal vaccines (if used outside a contained area and not approved in the US), animals, and

insects. This IEE does not authorize support for laboratory- or field-based research involving

GMOs/LMOs, nor does it authorize support for multiplication or dissemination/open release of

GMOs/LMOs. Support for laboratory research involving GMOs/LMOs in contained facilities

would require an approved amendment to this IEE. Support for field testing or open release of

GMOs/LMOs would require successful review under USAID’s Biosafety Procedures followed by

an approved IEE amendment. Nigerian national requirements must be met in either case. See the

Biosafety Procedures Factsheet for more information:

http://www.usaidgems.org/Documents/complianceTopics/Biosafety_5Feb2010.pdf

PESTICIDES: All activities that fall outside of the category of controlled experimentation

exclusively for the purpose of research and field evaluation and entail the procurement or use, or

both, of pesticides shall conform with the “Pesticide Evaluation and Safer Use Action Plan:

Maximizing Agricultural Revenue and Key Enterprises in Targeted sites II (Nigeria MARKETSII

PERSUAP_2013_2017)” approved 07/26/2013, conducted in accordance with USAID Pesticide

Procedures (22 CFR 216.3). See Environmental Compliance Database:

http://gemini.info.usaid.gov/egat/envcomp/repository/doc/39371.docx. Any pesticides NOT

covered by the existing MARKETS II PERSUAP will require an amended or new PERSUAP.

No new pesticide import, distribution or use is authorized for such activities not covered, unless

and until a PERSUAP is prepared in accordance with AFR Bureau guidance, fulfilling all

analytical elements required by 22CFR216.3(b), USAID’s Pesticide Procedures, and until said

assessment is approved by the BEO.

5.2 General Project Implementation and Monitoring

In addition to the specific conditions above, the negative determinations recommended in this IEE are

contingent on full implementation of the following general monitoring and implementation requirements:

1. IP Briefings on Environmental Compliance Responsibilities. The Economic Growth and

Environment Team shall provide each Implementing Partner (hereinafter IP), with a copy of this

IEE; each IP shall be briefed on their environmental compliance responsibilities by their

http://www.usaidgems.org/Documents/complianceTopics/Biosafety_5Feb2010.pdf



cognizant C/AOR. During this briefing, the IEE conditions applicable to the IP’s activities will be

identified.

2. Development of EMMP. Each IP whose activities are subject to one or more conditions set out

in section 3 of this IEE shall develop and provide for C/AOR review and approval an

Environmental Mitigation and Monitoring Plan (EMMP) documenting how their project will

implement and verify all IEE conditions that apply to their activities.

These EMMPs shall identify how the IP shall assure that IEE conditions that apply to activities

supported under subcontracts and sub-grants are implemented. (In the case of large sub-grants or

subcontracts, the IP may elect to require the sub-grantee/subcontractor to develop their own

EMMP.)

(Note: The AFR EMMP Factsheet provides EMMP guidance and sample EMMP formats:

http://www.usaidgems.org/Documents/lopDocs/ENCAP_EMMP_Factsheet_22Jul2011.pdf )

3. Integration and implementation of EMMP. Each IP shall integrate their EMMP into their

project work plan and budgets, implement the EMMP, and report on its implementation as an

element of regular project performance reporting.

IPs shall assure that sub-contractors and sub-grantees integrate implementation of IEE conditions,

where applicable, into their own project work plans and budgets and report on their

implementation as an element of sub-contract or grant performance reporting.

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

a. The Economic Growth and Environment team shall assure that any future contracts or

agreements for implementation of health portfolio activities, and/or significant

modification to current contracts/agreements shall reference and require compliance with

the conditions set out in this IEE, as required by ADS 204.3.4.a.6 and ADS 303.3.6.3.e.

b. IPs shall assure that future sub-contracts and sub-grant agreements, and/or significant

modifications to existing agreements, reference and require compliance with relevant

elements of these conditions.

5. Assurance of sub-grantee and sub-contractor capacity and compliance. IPs shall assure that

sub-grantees and subcontractors have the capability to implement the relevant requirements of this

IEE. The IP shall, as and if appropriate, provide training to sub-grantees and subcontractors in their

environmental compliance responsibilities and in environmentally sound design and management

(ESDM) of their activities. See Annex 6.

6. Economic Growth Team monitoring responsibility. As required by ADS 204.3.4, the Economic

Growth and Environment Team is responsible for on-going monitoring and evaluation of whether

the environmental components designed for the activity resulting from the 22 CFR 216 process are

being implemented effectively. This includes identifying and addressing new or unforeseen

environmental consequences arising during implementation.This will be achieved regular site visits

using the EGE field observation and pesticides use checklists.

7. New or modified activities. As part of its Work Plan, and all Annual Work Plans thereafter, IPs, in

collaboration with their C/AOR, shall review all on-going and planned activities to determine if

they are within the scope of this IEE.

If activities outside the scope of this IEE are planned, the Economic Growth and Environment

Team shall assure that an amendment to this IEE addressing these activities is prepared and

approved prior to implementation of any such activities.

http://www.usaidgems.org/Documents/lopDocs/ENCAP_EMMP_Factsheet_22Jul2011.pdf


Any ongoing activities found to be outside the scope of the approved Regulation 216 environmental

documentation shall be modified to comply or halted until an amendment to the documentation is

submitted approved.

8. Compliance with Host Country Requirements. Nothing in this IEE substitutes for or supersedes

IP, sub-grantee and subcontractor responsibility for compliance with all applicable host country

laws and regulations. The IP, sub-grantees and subcontractor must comply with host country

environmental regulations unless otherwise directed in writing by USAID. However, in case of

conflict between host country and USAID regulations, the latter shall govern.

ANNEXES

List of Annexes:

Annex 1: List of the awards that are active @ September 30, 2013


Annex 3: USAID Africa Bureau Fertilizer Information Sheet

Annex 4: DCA Loan Agreement Conditions

Annex 5: Environmental Mitigation and Monitoring Plan (EMMP) Template Annex 6: Environmental Screening Form for Sub-grant/New Activities Proposed under USAID/Nigeria DO 2 Annex 7: Draft Environmental Mitigation and Monitoring Plan for Small scale water supply

Annex 8: Category of Mandatory EIA studies in Nigeria

Annex 9: Standard Chartered Bank (UK) and Zenith Bank Nigeria Environmental and Social Responsibility

Policies


Annex 1. List of the awards that are active and/or planned as of September 30,

2013 and covered in this DO 2 EGE IEE for USAID Nigeria.

S/N Project

Name

LOP

Funding

($)

Objectives/Description Start

Date

End

Date

Geographic

coverage

(States)

Comment

TRADE & INVESTMENT: Trade and Investment Capacity

1 Nigeria

Expanded

Trade and

Transport

(NEXTT)

12,000,000 USAID’s Nigeria Expanded Trade

and Transport (NEXTT) program

aims to promote inclusive economic

growth and food security through an

integrated approach to trade and

transport competitiveness.

Oct,

2012

Sept,

2016

The eight-

state Lagos-

Kano-Jibiya

transportatio

n

corridor.

Lagos, Ogun,

Oyo, Kwara,

Niger,

Kaduna,

Kano &

Katsina

2 DCA

Loan

portfolio

guarantees

(LPGs)

985,526 The guarantee aims to support

banks’ expansion into funding

projects in agribusiness (non-

renewable energy activities) and

renewable energy activities

involving solar, biomass, hydro,

wind, clean cook stoves, and energy

efficiency activities by small- and

medium-sized enterprises (SMEs),

thereby increasing access to finance

on positive terms to creditworthy

but underserved potential clients.

Sept

2012

Sept

2017

National Addressed in

Nigeria

Renewable

Energy IEE

(see face

sheet) and the

present DO 2

IEE

Sub Total 16, 985,526

AGRICULTURE: Agricultural Enabling Environment

3

Nigeria

Strategy

Support

Program

(NSSP)

8,000,000

To assist the Ministry of Agriculture

and Rural Development’s

Department of Policy, Planning,

Analysis and Statistics will establish

a Comprehensive African

Agriculture Development Program

(CAADP) node at the Ministry

along with a research program

leading to evidence based policy

formulation.

Sept

30,

2010

Sept 30,

2014

National

4 Africa

Leadership

and Capacity

Building

Program

(Africa

LEAD)

450,000 Strengthen the ability of national

and regional public and private

sector organizations, private

producers’ and traders’ associations

to gain skills in a variety of

technical areas to support the

implementation of the CAADP at

country and regional levels.

Sept

13,

2010

Sept 30,

2013

National Likely to be

extended

into the

CDCS

years.

5 Nigeria

Agriculture

900,000 To enhance the capacity of GON to

develop the agricultural statistics

Feb

2009 - Sept

2013


extended


S/N Project

Name

LOP

Funding

($)


Date

End

Date

Geographic

coverage

(States)

Comment

Capacity

Building

Program

and information systems, continue

promotion of food safety policy, and

other related agriculture policy

formulation.

into the

CDCS

years.

6 Program for

Biosafety

Systems (PBS)

200,000 To enhance the capacity of GON to

evaluate and address the crucial

issues related to policy and

implementation agricultural

biotechnology.

Results:

- Improved policy environment for

the safe use of biotechnology

- Improved capacity for

formulation, implementation and

regulation of biotechnology

- Increased Public Awareness and

Outreach

Sept

2010

–

Sept 30,

2013


extended

into the

CDCS

years.

7 FEWSNET 820,000 To identify and disseminate

information on problems in the food

supply system that potentially leads

to famine or other food-insecure

conditions in Nigeria

Nov

30,

2009

Sept 30,

2013

15 Northern

States

8 FtF Private

Sector

Development

Program

[Monitor-

Deloitte]

1,000,000 To assist USAID Nigeria to develop

country private sector action plans

for agricultural development and

USAID /Washington to develop a

private sector engagement strategy

in support of the Feed the Future

(FTF) initiative.

Sept,

2011

Sept,

2014

USAID HQ

manages.

Sub Total 11,370,000

AGRICULTURE: Agriculture Sector Capacity

9 Maximizing

Agricultural

Revenue and

Key

Enterprises in

Targeted Sites

(MARKETS

II)

60,732,079 Promoting improved productivity,

value-added processing and

commercialized agriculture with the

aim of increasing sales and jobs for

agriculture-related businesses.

Focus Value Chains

April

18,

2012

April

17,

2017

14 states and

FCT selected

in

collaboration

with FMARD

PERSUAP

in place

10

Expanded

Access to

Services for

Agricultural

Enterprises

(EASE)

1,300,000

To increase profitability of small

agricultural enterprises.

1) Strengthened Enterprise

Management Skills of Small-scale

Rural Enterprise (11,000 Clients)

2) Strengthened Commodity Value

Chains (Maize; Rice Cassava; +)

3) Improve Access to Financial

Services to Small-scale Rural

Dec

02,

2009

Sept 30,

2013

Benue,

Nassarawa

Bauchi &

Sokoto

Award

closed Sept

30, 2013


S/N Project

Name

LOP

Funding

($)


Date

End

Date

Geographic

coverage

(States)

Comment

Enterprise (11,000 Clients)

11 Support to

Vulnerable

Households

(SVH)

14,999,625 The purpose of the Support to

Vulnerable Households for

Accelerated Revenue Earnings

project, referred to throughout this

document by the shorter Support to

Vulnerable Households project, is to

strengthen the participation of an

estimated 42,000 very poor

households in rural economic

growth and to improve their

livelihoods, nutrition and health.

July

02,

2013

July 01,

2018

Sokoto State

and Federal

Capital

Territory

(FCT)

Project may

extend to

Jigawa

State

Addressed

in this IEE

Sub Total 88,401,704

ENVIRONMENT: Clean Productive Environment

12 Nigerian

Energy and

Climate

Change

Project -

Enhancing

Sustainable

Utility

Regulation

(ENSURE) –

NARUC

750,000 To transform the Nigerian

Electricity Regulatory Commission

(NERC) into a transparent and

publically accountable energy

regulator, especially with regard to

creating an enabling environment to

incentivize private participation in

clean electricity generation.

Nov

30,

2009 –

July 8,

2015

National

Addressed

in this IEE

13 Nigerian

Energy and

Climate

Change

Project -

Africa

Infrastructure

Project (AIP)

[Nexant Inc]

5,250,000 NECC aim is to assist the

Government of Nigeria to: (a)

reduce GHG emissions by

improving policies and measures

aimed at stopping gas flares and

expand the use of gas to produce

electricity, (b) improve the policy

and regulatory environments for

energy efficiency (EE) and the

independent generation of clean

energy, (c) build the capacity of the

private sector to negotiate long term

financing for renewable energy

(RE) project and; (d) Identify and

implement commercially viable

renewable energy projects to

develop the market in Nigeria.

Nov

30

2009 –

March

30 2014

National Addressed

in this IEE

14 Energy

Efficient

Cookstove

Projects

[ICEED]

1,299,946 The overall goal is to create a

template for reducing greenhouse

gas emissions and health risks

among women by improving the

efficiency of the use of fuel wood in

institutions.

April

2012

April

2015

Niger and

Ebonyi

States

Addressed

in this IEE

Sub Total 7,299,946

Grand Total 112,687,176



S/

N IEE Title Source PDF

Link

Amount

($)

Award Number Start

Date

End

Date

Country Coverage

Washington Managed

1 Sustainable

Water and

Sanitation in

Africa

(SUWASA)

EGAT 53-08

20,000,000 EPP-1-04-00019-00 Sept

2008

Dec

2011

Sub-Saharan

Africa

2 Associate

Award to

IPM CRSP-

Food Security

Initiative

EGAT 43-08 2,000,000 EPP-A-00-04-00016 Sept

2008

Sept

2013

Sub-Saharan

Africa

3 John

Ogonowski

and Doug

Bereuter

Farmer-to-

Farmer

Volunte...

EGAT 10-09 75,000,000 Multiple (LWA) FY

2008

FY

2012

Uganda, Kenya,

Tanzania, Angola,

Malawi, Egypt,

Mozambique, Nigeria

Georgia, Moldavia,

Lebanon, Haiti,

Guyana, Nicaragua

and Dominica

Republic

4 CABIO

Initiative

Maruca

Resistant

Cowpea Field

Trial in N...

EGAT 29-09 40,000 EEM-G-00-03-000015 2003 2013 Institute of

Agricultural

Research, (IAR)

Zaria, Nigeria

5 Monitoring

Entrepreneurs

hip in

Muslim-

Majority

Countries

EGAT 30-10 3,000,000 AFR/SD 4.5

Agriculture

FY10 FY15 Egypt, Nigeria,

Bangladesh, Pakistan

6 African

Diaspora

Marketplace

(ADM)

EGAT 31-10 1,400,000 N/A FY10 FY12 Ghana, Ethiopia,

Kenya, Liberia,

Nigeria, Sierra Leone

and Uganda

7 CABIO

Initiative

Maruca

resistant

cowpea field

trial in N...

EGAT 46-10 40,000 EEM-G-00-03-000015 2003 2013 Institute of

Agricultural

Research, (IAR)

Zaria, Nigeria

8 AFR/SD

mFarmer

Initiative

AFR-

SD_mFarmer_

CE_072211

AFR/SD 4.5

Agriculture

Sept

2011

Sept

2014

Ethiopia, Ghana,

Mali, Nigeria,

Mozambique,



S/

N IEE Title Source PDF

Link

Amount

($)

Award Number Start

Date

End

Date

Country Coverage

Tanzania, Kenya,

Malawi

9 Confined

field trial of

bioengineered

cowpea

resistant to... BFS 14-11

40,000 EEM-G-00-03-000015 2003 2013 Institute of

Agricultural

Research, (IAR)

Zaria, Nigeria

10 African

Cocoa

Initiative

GDA BFS 14-12

5,000,000 N/A FY11 FY16 Cote D’Ivoire

11 Post-Harvest

Storing and

Drying GDA BFS 14-13

2,000,000 N/A FY12 FY15 Kenya, Nigeria

12 SEA for

Indoor

Residual

Spraying for

Malaria

Control in N.

GH-12-009 GHN-I-01-09-00012 May

2012

Sept

2015

Nigeria

West Africa Regional Managed

13 West Africa

Seed Program

(WASP)

USAID-

WA_WASP_I

EE_070612

624-12-00005 Burkina Faso, Ghana,

Mali, Nigeria,

Senegal, Niger,

Liberia





Annex 3: USAID Africa Bureau Fertilizer Information Sheet Background: Low soil fertility is a problem throughout most of Sub-Saharan Africa (SSA). Moreover, the drastic reduction in fallow

periods and the almost continuous cropping without soil fertility restoration has depleted the nutrient base of most soils.

By the mid-late 1990s, all SSA countries were demonstrating a negative annual nutrient balance 1. Countries that have

the highest nutrient loss rates are the ones where fertilizer use is low and soil erosion is high. These areas include the

East African highlands and a number of countries in West Africa.

Low soil fertility is also a driving force behind the conversion of natural areas for agricultural extension. It is generally

accepted that agricultural intensification is the only viable means to conserve key natural areas while increasing food

security for the continents growing population and generating economic growth through improved agricultural

productivity. Land degradation undermines the ability of countries to move in this direction, and the loss of soil nutrients

is the most important contributing factor to the land degradation process. The use of inorganic fertilizers is a critical part

of the strategy to stop land degradation, restore soil fertility and better manage the soil resources that are fundamental for

sustainable agricultural and economic development.

Fertilizers and USAID Environmental Procedures (22 CFR 216) –

Fertilizers are frequently lumped together with pesticides under the generic heading of “agro- or agrichemicals.”

From an environmental compliance perspective (22 CFR 216), as well as from a field-level implementation point of

view, this is inappropriate, because it implies that fertilizers require the same level of scrutiny reserved for

pesticides. Whereas pesticides are subject to clearly defined environmental review procedures [22 CFR

216.3(b)(1)], and an approval process to promote safer use and integrated pest management, such procedures do not

apply to fertilizers (procurement procedures do apply to quantity bulk purchase). As with any technology, however,

it is recommended that fertilizers be thoughtfully employed according to best practice, promoting integrated soil

fertility management, within the context of the prevailing biophysical and socio-economic conditions, as well as the

desired outcomes. This fact sheet was developed to assist in that regard.

Importance of Water Management to Nutrient Uptake –

Proper water management is important for maximizing crop use of nutrients. About 97% of crop nutrient uptake is

from soil solution (water-soluble nutrients), which makes water by far the most important nutrient or fertilizer

delivery medium. This also means that, for the most part, nutrient mobility is directly linked to water movement. In

sandy soils, nutrients move more quickly through the root zone and soil profile than in other soil types, and

excessive water application (or heavy rainfall) can lead to nutrient loss through leaching. Run-off is most serious on

loamy-sands or sandy loams that often have a strong surface crust formation. In heavier soils (clays), if nutrients are

not adequately incorporated into the soil, the chances for surface runoff in the event of heavy rains or over-irrigation

are increased. Sound water management is especially important in rainfed conditions (common throughout SSA).

Overall, good water management leads to a more efficient use of fertilizers and increased nutrient uptake and vice

versa.

General Soil Fertility Trends in Africa --

Farmers who have taken measures to conserve moisture or increase soil organic matter are more likely to use

inorganic fertilizer. When farmers in some areas have capital, they often invest first in increasing moisture

retention and/or increasing soil organic matter and secondly in inorganic fertilizer.

Farmers increase their use of fertilizer when investing more money in fertilizer is seen to be the best available

option. This increase may result from changes in any of the following: fertilizer price, crop price, fertilizer

availability, water availability, seed availability, knowledge about fertilizer use, or cropping pattern.

In West Africa, integrated soil fertility management is progressively adopted. It concerns the combined use of

soil amendments and inorganic fertilizer, leading in time to improved soil fertility and increased fertilizer use

efficiency and profitability. The nutrient losses to the environment are decreasing.

Given past and current use rates, USAID’s fertilizer-related activities in Africa are unlikely to cause

environmental problems.

Fertilizer Application guidelines --

Before applying fertilizers, obtain an assessment of soil conditions (fertility).


Indiscriminate use of chemical fertilizers should be avoided.

Different kinds of fertilizers are required in order to maintain a given level of soil fertility. This depends on

site-specific factors, including the soil type, the nutrient requirement of the crop and the various sources of

available nutrients. Nitrogen and Phosphorous are the most important nutrients lacking in SSA soils.

Fertilizer application has to be considered in the context of the overall farming system. This includes the use

of organic manure and residues, soil cultivation and crop rotation and water harvesting. Collectively, these

factors influence the efficiency of nutrient use.

When fertilizers are used, it is very important to apply the correct amount for the given situation. The

challenge to the farmer is to match as closely as possible the input of nutrients to the nutrient uptake of the

crop, thereby minimizing losses. Over fertilization is both costly (wasteful) and potentially harmful to the

environment. To apply the correct amount, the farmer has to define his production goal.

Potential negative environmental effects of fertilizers --

Excessive application of nutrients over time can cause pollution. Such losses may occur when nutrients run off the

land caused by heavy rainfall, are leached through the soil, beyond the root zone, eventually reaching the

groundwater, or escape into the atmosphere as volatile gases.

Aspects of environmental impact can be illustrated as follows:

(Taken from Incitec Fertilizers)

Nitrogen fertilizers: Inorganic nitrogen fertilizers are readily converted by soil organisms to nitrate in the soil. The

nitrogen in soil organic matter and organic fertilizers becomes available more slowly. Nitrates may be readily

leached if not used by crops or other vegetation. Leaching is particularly likely in sandy soils following heavy

rainfall. Leached nitrates may contaminate underground water. This is of concern if the water is to be used for

human or livestock consumption, as high concentrations of nitrate may affect health.

Nitrogen fertilizers can also accelerate the natural process of soil acidification. Some fertilizers (e.g. anhydrous

ammonia and urea) may initially raise the soil pH at the site of application but in the long term acidify the soils. This

occurs when ammonium is converted to nitrate. Acid produced in the nitrification process is used if the nitrate is

taken up by plants or soil organisms, but if the nitrate is leached beyond the root zone, acidification occurs. Soil

acidification reduces the availability of the trace element molybdenum, fosters the development of aluminum, iron

and manganese toxicity and increases nodulation failure in legumes. Lime may be required where acidity is a

problem (obtained from naturally occurring calcium carbonate) or the use of acid tolerant plant species can be

considered. An illustrative list of crops with acid tolerant varieties include: rice, cassava, mango, cashew, citrus,

pineapple and cowpeas.

Phosphorus fertilizers: Excess amounts of phosphorus have been associated with algal blooms and the

eutrophication of lakes and waterways. In most waters, phosphorous functions as a growth-limiting factor because it

is usually present in very low concentrations. Algae only require small amounts of phosphorous to live. Excessive

phosphorus over-stimulates the growth of algae, which could deplete the water of the dissolved oxygen that is vital

to other aquatic life. Phosphorus is relatively immobile in the soil, so conservation and cultural practices which

reduce soil erosion can significantly reduce phosphorus inputs into water bodies and the water table.

Phosphorus fertilizers contain various impurities from the phosphate rock and acid used in manufacturing the

fertilizer. Cadmium increases is the greatest concern as its compounds are toxic to human beings. Cadmium

increases are most noticeable in certain crops e.g. potatoes and leafy vegetables (lettuce and spinach) and in the


organs (kidneys and liver) of animals. Almost all phosphate fertilizers contain traces of cadmium, and the

concentration of cadmium varies considerably from source to source. At this time, there are efforts underway in

West Africa to develop viable processes to remove cadmium from phosphate rock. Exports of rock phosphate

represent a vital source of revenue for a number of developing countries in Africa.

Fertilizer Effects on Soil Biology: Good soil consists of 93% mineral and 7% bio-organic substances. The bio-

organic parts are humus (85%), roots (10%) and soil organisms (5%). Most of the soil organisms are decomposers

(bacteria and fungi), which are responsible for nutrient retention in soil. In order for nutrients to become available

they must be mineralized by the interaction of decomposers and organisms that feed on the decomposers (protozoa,

nematodes, micorarthropods and earthworms). Plant growth is dependent on microbial nutrient immobilization.

When the number of decomposers declines in soils, more nutrients are lost into the ground and surface water.

Heavy treatments of chemical fertilizers can kill decomposers and other soil organisms, which will lead to a

reduction in nutrient retention and possible surface and ground water contamination.

A summary of best management practices for soil fertility and health --

Practice Integrated Soil Fertility Management (ISFM) – the use of both organic and inorganic sources of

nutrients rather than either alone;

Use of legume cover crops (plus phosphorous) and green manures by fallow rotation or intercropping;

Promote agroforestry practices – in addition to soil conservation and production benefits, agroforestry

transfers/cycles nutrients from within the soil profile (deeper levels to surface);

Use conservation tillage rather than deep plowing (although conservation tillage can be harmful for

production systems in certain regions 2);

Use farm site manures and household wastes, with or without composting;

Choose crops and associated plants that have high nutrient use efficiency.

End Notes:

1. Henao, J. and Baanante, C. 1999. Estimating rates of nutrient depletion in soils of agricultural lands

of Africa. Technical Bulletin. IFDC – T 48. IFDC, Muscle Shoals, Alabama. 76p.

2. Hoogmoed, W. 1999. Tillage for soil and water conservation in the semi-arid tropics. Phd thesis,

Wageningen University, Holland.

Acknowledgement: This fact sheet was strengthened by a thoughtful technical review by Dr. Henk Bremen, Director

of Africa Division, International Center for Soil Fertility and Agricultural Development (IFDC), Lome, Togo.

June 2004.


Annex 4: DCA Loan Agreement Conditions: First Order Screening

The Loan must not be used to finance any of the following without the prior written

approval of USAID:

(1) Pharmaceuticals,

(2) Pesticides,

(3) Logging equipment,

(4) Luxury goods (including alcoholic beverages and jewelry),

(5) Establishing or expanding any enterprise that will export raw materials that are likely to be in

surplus in world markets at the time such production becomes effective and that are likely to

cause substantial injury to U.S. producers,

(6) Activities which would result in the loss of forest lands due to livestock rearing, road construction

or maintenance, colonization of forest lands or construction of dams or other water control

structures,

(7) Activities which are likely to have a significant adverse effect on the environment, including any

of the following (to the extent such activities are likely to have a significant adverse impact on the

environment):

(a) programs of river basin development,

(b) significant irrigation or water management projects (including dams and impoundments),

(c) agricultural land leveling,

(d) major drainage projects,

(e) large scale agricultural mechanization,

(f) new lands development,

(g) resettlement projects,

(h) penetration road building or road improvement projects,

(i) construction of power plants or industrial plants, or

(j) large scale potable water and sewerage projects,

(8) Activities which are likely to involve the loss of jobs in the United States due to the relocation or

expansion outside of the United States of an enterprise located in the United States, or

(9) Activities which the Guaranteed Parties are aware are likely to reasonably contribute to the

violation of internationally recognized rights of workers.

Approval of loans to finance the purchase or use of pesticides, will be contingent upon the submission by the

Guaranteed Party and approval by BEO of a supplemental Initial Environmental Examination meeting USAID

Pesticide Procedures [22CFR216.3(b)].

Excerpt from approved IEE for Nigeria Development Credit Authority (DCA) Renewable Energy. See


Regarding the potential for financing investments will be ultimately result in construction of power-related

infrastructure

Nigeria Renewable Energy DCA:

Negative Determination is recommended pursuant to 22 CFR 216.3(a)(2)(iii) for this DCA loan guarantee

to First Bank and Ecobank loans to increase access to finance for the renewable energy, energy efficiency

and agribusiness Small and Medium Enterprises (SMEs) in Nigeria subject to the conditions that:

The EGE team with support of the MEO shall ensure that the Guaranteed Parties have environmental

screening system sufficient to demonstrate compliance with Nigeria Environmental Impact Assessment



(EIA) Act. Cap E12, LFN 2004 and to enable USAID to make an assessment of the environmental

impact of such activities and shall submit to USAID their policies and procedures to assure that the

projects financed are environmentally sound and comply with applicable laws and procedures.

The Guaranteed Parties shall seek prior USAID approval and submit evidence of environmental

compliance before placing certain types of loans under Guarantee coverage as specified in section

2.02(b) of the Development Guarantee Agreement annexed to this IEE. (Appendix A)

The Loan must not be used to finance activities which significantl y degrade national parks or similar

protected areas or introduce exotic plants or animals into such areas.

The EGE team must ensure that the activities of the guaranteed parties are actively monitored for

compliance with approved IEE recommendations and the USAID/Nigeria MEO will periodically review

the Guaranteed Parties implementation of these requirements through regular field visits.

Note added April 7, 2014, upon receipt from USAID Nigeria three Ecobank files regarding progress made since the

original IEE was submitted in November 2012: a) the Guarantee Agreement, b) transaction report summary, and c)

Ecobank's Environmental & Social Assessment Polices & Procedures. It appears that First Bank is dropping out of

the DCA.


Annex 5: Environmental Mitigation and Monitoring Plan (EMMP)

An EMMP should be developed for all activities under this DO that have at least one “Negative

Determination with Conditions”

The implementing partner should usually lead development of the EMMP, subject to review and

oversight by the MEO and A/COR. In all cases, the tasks identified in the EMMP are incorporated into

the implementing partner’s Work Plan, budget, and reporting.

The following EMMP format is recommended. It can be adapted, as necessary. Note: The AFR EMMP

Factsheet provides EMMP guidance and sample EMMP formats is available at:

http://www.usaidgems.org/Documents/lopDocs/ENCAP_EMMP_Factsheet_22Jul2011.pdf )

USAID/Nigeria: Recommended EMMP template:

---------------------------------------------------------------------------

Environmental Mitigation and Monitoring Plan

Activity Title:

Implementing Partner:

Activity Mitigation

measure(s)

Monitoring

indicator(s)

Monitoring and

Reporting

Frequency

Party or Parties

responsible.

List all activities

in IEE that

received a

“negative

determination

with conditions.”

Do not list any

other activities.

If mitigation

measures are

well-specified in

the IEE, quote

directly from IEE

If they are not

well-specified in

the IEE, define

more specifically

here.

Specify

indicators to (1)

determine if

mitigation is in

place and (2)

successful.

For example,

visual

inspections for

seepage around

pit latrine;

sedimentation at

stream crossings,

etc.)

For example:

“monitor weekly,

and report in

quarterly reports.

If XXX occurs,

immediately

inform USAID

activity

manager.”

If appropriate,

separately

specify the

parties

responsible for

mitigation, for

monitoring and

for reporting.

USAID/Nigeria

EMMP Reporting form

http://www.usaidgems.org/Documents/lopDocs/ENCAP_EMMP_Factsheet_22Jul2011.pdf


List each Mitigation

Measure in the

EMMP

Status of Mitigative

Measures

List any outstanding

issues relating to

required conditions

Remarks

Certification

I certify the completeness and the accuracy of the mitigation and monitoring plan described above

for which I am responsible and its compliance with the DO IEE:

Signature Date

Print Name

__________________________

Organization

BELOW THIS LINE FOR USAID USE ONLY

USAID/Nigeria Clearance of EMMR:

Agreement/Contracting Officer Representative (A/COR): _______________ Date: _____________

Mission Environmental Officer: ______________________ Date: ____________

As appropriate: REA, BEO [depending on nature of activity, which potentially may require an EA]

Note: if clearance is denied, comments must be provided to applicant


Annex 6: Environmental Screening Form for Sub-grant/New Activities

Proposed under USAID/Nigeria DO 2

Any Implementing Partner proposing an activity which is not covered by the existing USAID/Nigeria

DO2 IEE must complete the “Environmental Screening Form” UNLESS the project or activity is carried

out to address an emergency (e.g., international disaster assistance). Emergencies are determined by the

US Ambassador, not by the applicant. Per CFR §216.2(b)(1), most activities carried out under emergency

circumstances are considered EXEMPT from environmental procedures, except for the procurement or

use of pesticides.

The proposed activity cannot be approved and no funds may be committed until the environmental

documentation, including mitigation measures, is cleared by the A/COR and approved by the

USAID/Nigeria Mission Environmental Officer (MEO). USAID may request modifications, or reject the

documentation. If the activities are found to have significant adverse impacts, a full Environmental

Assessment must be conducted.

The instructions and the form can be found, under “Subsidiary Review,” at the following web site:




Annex 7: Draft Environmental Mitigation and Monitoring Plan for Small

scale water supply

Implementing Partner: Various

Activity Mitigation measure(s)

Monitoring indicator(s)

Monitoring and

Reporting Frequency

Party or Parties

responsible.

Construction of

small scale water

supply and

sanitation

infrastructure

Survey will be done to avoid siting of all

water supply and sanitation infrastructure

in sensitive ecological areas.

Construction sites will be carefully

selected to minimize damage to

vegetation that could cause erosion. Data

on soil type will be gathered to determine

the potential for significant erosion. Any

vegetation that is damaged during

construction will be replanted before the

conclusion of the project.

Construction procedures will follow

USAID guidelines and construction

workers will be monitored to ensure best

practices in construction are maintained

and followed.

Proper bedding materials will be used for

the pipes.

Proper drainage provided for runoff water

to avoid pools and stagnant water.

Photos, Reports

and

documentation

Onsite

monitoring &

supervision

Onsite

monitoring &

supervision.

Throughout

duration of

construction

activities

Implementing

Partner

Water Yield

Sustainability

Hydrogeological analysis will be

conducted prior to constructing the water

point to certify that the yield of each well

is sufficient for the anticipated demand.

Facilities will be strategically located to

ensure local warden is available to

regulate water use at the points to avoid

overuse or wastage.

Water and Environmental Sanitation

committees will monitor and repair leaks

from cracked containment structures,

broken pipes, faulty valves and similar

structures to eliminate sources of water

wastage. Plumbers will be trained by the

Implementing Partner of the Collaborating

State Water and Sanitation Agency to

oversee the maintenance and operation of

the water facilities.

Water Quality Depth of water table will be evaluated to




Monitoring and

Reporting Frequency

Party or Parties

responsible.

Assurance

ensure pit latrines are installed

appropriately such that the water table is

not contaminated.

Locations for latrines and boreholes will

be selected with feedback from

community members and local Water and

Environmental Sanitation Committees.

After drilling, boreholes will be cased

and filled with gravel to prevent

contamination

Water quality testing will be conducted

on all water points constructed to ensure

that government quality standards are

met and it is safe to drink, as well as to

establish a baseline so that any future

degradation can be detected. . Water

samples collected will be taken to

government laboratory or any competent

water testing authority for physical,

chemical and bacteriological analysis

before being put in for any human

consumption. The water quality

assessment will test for: pH value,

appearance, taste, turbidity, conductivity,

arsenic, iron, magnesium, nitrate, copper,

fluoride, free carbon dioxide, hardness,

alkalinity, silica, manganese, nitrate,

ammoniacal nitrogen, and

microbiological parameters.

Water quality assessments will include

tests for the presence of arsenic as

required by Guidance Cable State 98

108651 and articulated in the EGAT and

Africa Bureau guideline document titled,

“Guidelines for Determining the Arsenic

Content of Ground Water in USAID-

Sponsored Well Programs in Sub-

Saharan Africa.” The project team will

ensure that the standards and testing

procedures described in this guideline

document are followed for potable water

points developed or renovated as part of

project activities.

Activity will promote implementation of

a long-term monitoring system in

conjunction with the municipality:

Establish baseline of water quality

through testing for chemical and

http://www.encapafrica.org/EGSSAA/Word_English/Watsan.doc







Monitoring and

Reporting Frequency

Party or Parties

responsible.

biological contaminants in borehole

water (P&D)

Ensure regular testing of water quality

through incorporation of water testing in

handover plan to municipality and

community education (O&M)

Relevant local community rules and best

practices and procedures of promotion of

better environmental health will be

developed and adhered to. Verification

through site visits and photos would be

done to assure practices are in

accordance with local community rules

and “best practices”

Maintenance and

Sustainability

Plan

Community water and sanitation

committees will be established and

trained to manage, repair and maintain all

water and sanitation points, including

cost recovery and financial management.

The training will include proper

techniques for watering of livestock and

hygiene education.

Training in sanitation and hygiene for

water committees, communities, area

based development groups, and/or

municipal water board members will be

carried out to:

o Ensure community

mobilization and public

awareness of human health

risks associated with water-

borne disease vectors

o Encourage the development of

community responses that are

environmentally sound, cost

effective, and safe; and

Ensure control over the management of

the facilities and operations that USAID

is supporting.


Annex 8: Select Project Categories for Mandatory EIAs in Nigeria

Project

Category

Project Type Other considerations

1 Agriculture/Agro allied

Industry/manufacturing

Food, Beverage, Tobacco processing.

Infrastructure: Ports, Housing, Airport,

Drainage and Irrigation, Railway.

Transportation; Resort and Recreational

development, Power Generation; Petroleum,

Mining, Quarries, Waste Treatment and

Disposal, Water Supply; Land Reclamation

and Brewery.

2 Agricultural/rural development

Reforestation/afforestation project; small scale

irrigation; small scale aquaculture, Saw

milling, Logging, Rubber processing, fish

processing

Industry/Infrastructure

Mini-hydropower development, any small

scale industry development e.g., textiles,

chemical industry, power transmission,

renewable energy development,

telecommunication facility, rural water

supply, Public hospitals, road rehabilitation.

Small scale tourism development. Any form

of quarry or mining.

If the project is located in:

environmental sensitive areas,

e.g., coral reefs, mangroves

swamps, small islands. Tropical

rainforest, area erosion prone to

soils like mountain slope, area

prone to desertification, wetlands

of national or international

importance, areas with

protected/endangered species,

areas of unique scenery, areas of

scientific interest, areas of historic

or archeological interest.

Moves to category 1

3 Institutional development, health family

planning, nutritional and education programs.

If project involves physical

interventions in the environment

Moves to category 2

Source: Federal Ministry of Environment, 1995.


Annex 9. Standard Chartered Bank (UK) and Zenith Bank Nigeria Environmental and Social Responsibility Policies


Environmental Policy

Standard Chartered is an international bank, leading the way in Asia, Africa and the

Middle East. We recognise that through our business operations, we inevitably

impact upon the natural and physical environment, either directly or indirectly.

We are committed to minimizing the environmental effects of our operations and

aim to achieve continual improvement in our management of environmental issues.

Because our operations span a wide range of countries with differing cultures,

climates, infrastructures and legal requirements, we have developed a number of

environmental commitments that can be applied universally across the organisation.

These are as follows:

Legal Compliance We aim to comply fully with all government legislation applicable in each country in

which we operate. Where no regulations apply, we will adopt our own International

Environmental Standards.

Energy and Resource Use We will seek to reduce our per capita consumption of resources, specifically: energy,

water, transportation services and paper, wherever practicable opportunities exist.

Hazardous Substances We areendeavouringto eradicate the use of ozone depleting substances and to

use only refrigerants with a low global warming potential in Standard Chartered

controlled premises.

Hazardous substance use is managed to ensure that releases are minimized both

during operation and at the end of life.

Procurement Our major operational centre procurement processes consider environmental

issues surrounding the production, consumption and disposal of products and

services.

Wherever practicable, we procure products derived from sustainable resources.

Wherever appropriate, we favour the use of suppliers who can demonstrate

environmentally sound business practices.

Banking Services We give due consideration to the presence of environmental and social risks in our


banking transactions.

We expect our banking customers to comply with the prevailing environmental and

social regulations applicable to their sphere of operation.

Air Emissions and Waste Management We identify, record and monitor greenhouse gas emissions arising from our

activities, wherever our global environmental management system is

implemented and reliable means to do so exist.

When possible, targets for reducing our greenhouse gas emissions will be set and

progress towards them will be reported annually.

Wherever practical, we seek to minimize the production of wastes, and encourage

staff to participate in reuse and recycling initiatives.

We ensure that wastes that are not reused or recycled are disposed of in a

safe and responsible manner.

These commitments are implemented through appropriate management controls,

including our global environmental management system (GEMS) and our

environmental and social credit risk assessment processes. In order to measure our

progress, we set management and/or performance targets, and monitor and report

on our progress.

We welcome the participation of our staff, customers and the public in this

process. To facilitate this we are developing staff awareness through

training and internal communications, and invite feedback from other

stakeholders on our performance.

We will continue to prepare a publicly available environmental report annually,

and undertake periodic reviews of our policy and targets.

A Group Executive Director is responsible for environmental managements and

provides regular reports on progress to the Board.