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INITIAL ENVIRONMENTAL EXAMINATIONOR

CATEGORICAL EXCLUSION

PROGRAM/ACTIVITY DATA:

Program/Activity Number: Regional Peace and Governance Office (RPGO)

Country/Region: West Africa

Program/Activity Title: Promote Conflict Mitigation and Regional Stability

Funding Begin: FY13 Funding End: FY2018 LOP Amount: $250,000,000

IEE Prepared By: Benjamin Opoku, Regional Environmental Compliance Specialist, WA

Robert Kevlihan, Senior Program Management Specialist, RPGO, WA Nana Serwaa Bonsu Amoako, Program Management Specialist

Current Date: 02/25/2013

IEE Expiration Date: 09/30/2018

IEE Amendment (Y/N): Y

If Yes, File Name and Date of Original IEE: RPGO Programmatic IEE dated September 26, 2011 (USAID-WA_RPGO_IEE_092611) and the amended version dated 04/12/12

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)

Categorical Exclusion: ___X___ Negative Determination: __X___

Positive Determination: ______ Deferral: __X___

ADDITIONAL ELEMENTS: (Place X where applicable)

CONDITIONS ____X______ PVO/NGO: __________

SUMMARY OF FINDINGS:

Purpose and Scope of the IEE

The West Africa Regional Peace and Governance Office has been operating under an umbrella IEE for its Regional Conflict Mitigation and Stability Program. This was approved and dated 09/26/2011 with file number USAID_WA_RPGO_IEE_092611. An amendment to the original umbrella IEE was subsequently developed to include Increasing Transparency and Accountability in the Management of Natural Resources in Niger which was approved and dated 4/12/12 with file number USAID_WA_RPGO_IEE_041212.

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The purpose of this IEE is to consolidate the original umbrella IEE and its subsequent amendment into a single document, extend the date of the determinations of the original IEE, and to add new activities. New activities to be added are outlined in sections 3.5 and 3.6 of this IEE. Thus, this IEE REPLACES the original umbrella and its amendment thereof.

Recommended Determinations and Conditions

Recommended Determinations and in some cases attendant conditions for all activities under the RPGO consolidated umbrella IEE can be found sections in 3.0-3.10 of this IEE.

The objectives of the Regional Peace and Governance Office include:

Promote peace through development Strengthen state and communities’ resiliencies to extremism Strengthen indigenous institutions to promote elections, accountability and civic engagement Promote consensus-building and the development of democratic institutions and political processes Strengthen public accountability, transparency and respect for the rule of law and human rights \ Enhance the capacity of legislators to enact laws, regulations, improve administration and access to

justice. Foster communication and collaboration between the legislature and select CSOs on enactment of

legislation. Enhance access to quality education at selected project schools.

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APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:

WA Regional Peace and Governance Consolidated Umbrella IEE

CLEARANCE:

Mission Director: ________________________________ Date: ________ Carlene Dei (Interim Mission Director)

CONCURRENCE:Bureau Env. Officer: ________________________ Date: ________

Brian Hirsch

Approved: _________ Filename: _____________

Disapproved: _________

ADDITIONAL CLEARANCES:

Office Director: ________________________________ Date: _________Robert Kevlihan (Acting Head, RPGO, USAID W/A)

Mission Environment Officer: ______________________________________________ Date: _________________Benjamin Opoku

Regional EnvironmentalAdvisor (REA) ________________________________ Date: _________ Anne Dix

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INITIAL ENVIRONMENTAL EXAMINATION

PROGRAM/ACTIVITY DATA:Program/Activity Number: Peace and GovernanceCountry/Region: West AfricaProgram/Activity Title: Promote conflict mitigation and regional stability

1.0 BACKGROUND AND PROJECT DESCRIPTION

1.1 Background – USAID West Africa Regional Mission

The West Africa Mission (USAID/WA) based in Accra, Ghana, was created by USAID as a response to development challenges at the regional level throughout West Africa. WA operates as an independent mission, cooperating assistance with 21 countries. 1 Partners of WA include many intergovernmental organizations, chief of which is the Economic Community of West African States (ECOWAS). WA supports ECOWAS priority programs in the areas of conflict prevention, regional economic integration, policy harmonization, and HIV/AIDS.

The goal of USAID/WA is to assist in the development of a politically stable and economically prosperous West Africa. In order to do this the USAID Mission supports five objectives:

Agricultural Productivity and Food Security Enhanced (former SO8) now the Regional Agriculture Office

Increased Adoption of Selected High Impact Health Policies and Approaches (former SO9) now Health Office

Reduce vulnerability to climate change in West Africa by strengthening the resilience of natural resource base to climate change in target areas. (i.e. overall objective of ROECCR)

Greater Trade Competitiveness (former SO 11) – now Trade Office Promote Conflict Mitigation and Stability (former SO12) – now the Regional Peace and Governance

Office

USAID/WA seeks to integrate the activities of these offices throughout their implementation to produce results that are synergistic – having greater impact than if these activities were undertaken separately without regard to each other.

1.2 Purpose and Scope of IEE

The West Africa Regional Peace and Governance Office has been operating under an umbrella IEE for its Regional Conflict Mitigation and Stability Program. This was approved and dated 09/26/2011 with file number USAID_WA_RPGO_IEE_092611. An amendment to the original umbrella IEE was subsequently made to include Increasing Transparency and Accountability in the Management of Natural Resources in Niger which was approved and dated 4/12/12 with file number USAID_WA_RPGO_IEE_041212.

The purpose of this IEE is to consolidate the original umbrella IEE and its subsequent amendment into a single document, extend the date of the determinations of the original IEE, and to add new activities. New activities to be added are outlined in sections 3.5 and 3.6 of this IEE. Thus, this IEE REPLACES the original umbrella and its amendment thereof.

1.3 Overview: Peace and Governance Office Conflict Mitigation and Regional Stability Program

1 The 21 countries supported by USAID/WA include Benin, Burkina Faso, Cameroon, Cape Verde, Chad, Cote d’Ivoire, Equatorial Guinea, Gabon, Gambia, Ghana, Guinea, Guinea-Bissau, Liberia, Mali, Mauritania, Niger, Nigeria, Sao Tome and Principe, Senegal, Sierra Leone and Togo. Of these countries, 15 are members of ECOWAS (Benin, Burkina Faso, Cape Verde, Cote d’Ivoire, Gambia, Ghana, Guinea, Guinea-Bissau, Liberia, Mali, Niger, Nigeria, Senegal, Sierra Leone and Togo).

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Political stability and security in the region, which are the basis of development as well as US security interests, require conflict prevention and mitigation activities, collaboratively carried out by the public, private sectors and civil society organizations. Nowhere is this more evident than in West Africa and the Trans-Sahel where the issues of violent religious extremism and external forces of disruption have become dangerously pronounced and continue to impede stable development, while the management and governance of natural resources has proven problematic both in environmental and conflict terms. Unresolved land disputes, illicit trade in commodities and labor conflicts around extractive industries all feed into the dynamics of armed conflict in the region.

USAID/WA proposes both an innovative and pragmatic forward-looking regional approach to promote peace and security, governing justly and democratically and finally strengthen resiliencies of targeted communities over the next five years. Developing and reinforcing the capacities of key institutional and civil-society partners, especially ECOWAS, is paramount to promoting peace, conflict mitigation and good governance in West Africa.

2.0 COUNTRY AND ENVIRONMENTAL INFORMATION (BASELINE INFORMATION)

West Africa is a region that continues to address the challenges of good governance and democratization while dealing with treats of violence and, in some countries, violent religious extremism. The post-election violence in Cote d’Ivoire highlights the continued risks that can be caused in situations where the norms of democratic governance – including free and fair elections and the peaceful transfer of power – have not been sufficiently institutionalized and integrated into the political life of a country. Despite significant progress made in this area within the region, most notably in Ghana, which has experienced peaceful transfers of power despite very close run electoral races, West African states remain vulnerable to both localized and more general violence related to governance and electoral cycles. The region is also host to organizations that use violence and terrorism to advance their extremist religious agendas – most notably Al Qaida in the Maghreb (which in the region operates mainly in Mauritania, Niger and Mali) and Boko Haram, an organization based in northern Nigeria.

These political challenges can be compounded by on-going risks of environmental degradation, particularly in the fragile Sahel region. Management and governance of natural resources have also proven problematic both in environmental and conflict terms. Unresolved land disputes, poverty, competition over diminishing natural resources, illicit trade in commodities and labor conflicts around extractive industries can all feed into the dynamics of armed conflict in the region. Addressing issues of good governance, peace and stability in the region are essential in order to protect development gains already made and provide a secure platform upon which the people of West Africa can continue to improve their lives.

3.0 POTENTIAL ENVIRONMENTAL IMPACTS AND RECCOMMENDED DETERMINATIONS INCLUDING CONDITIONS

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For purposes of environmental review, activities within the RPGO Conflict Mitigation and Regional Stability program are grouped under the following intervention categories;

1. Assessment of legislature, civil society organizations (CSO), media, judiciary and court staff capacity with respect to fulfilling its basic legislative, judicial, representational and oversight functions.

2. Training and capacity building in the fields of peace, democratic governance, counter extremism, rule of law, legislation enactment /strengthening, administration of justice and teachers.

3. Small scale infrastructure construction and rehabilitation activities 4. Livelihood support training and technical assistance in vocational activities5. Waste/Refuse Clearance, Collection, Disposal and Drainage Clearance Activities 6. Small grants activities

3.1 Assessment of legislature, civil society organizations (CSO), media, judiciary and court staff capacity with respect to fulfilling its basic legislative, judicial, representational and oversight functions.

The illustrative activities contained within this category include:

1. Assessment of legislative needs related to oversight of parliamentary procedures and processes. 2. CSO’s and media capacity assessment to deliver program and representational functions. 3. Assessment of judiciary, police and court staff related to oversight of justice services. 4. Assessment of legislative needs related to oversight of natural resources management. 5. Civil society assessment of CSOs active in the areas of government oversight and natural resource

management, and selection of partner CSOs.

Potential Adverse Impacts & Considerations Regarding Recommended Determinations on NRM.

The activities in category 4 &5 are intended to assess legislative and civil society capacity at various levels to engage in the oversight and governance of natural resource management. These activities conform to a class of interventions that may be eligible for Categorical Exclusion.

However, natural resource management (NRM) activities, specifically the extractive industries, do have potential, perhaps significant, adverse impacts on critical environmental resources and human health. Ineffective or absent technical oversight of extractive industry activities may exacerbate these risks. Failure to adequately assess the capacity of the legislature or CSOs to understand the governance implications of these risks may result in environmental issues being given inadequate attention in future implementation of natural resource management activities.

In addition, some assessments may be used to select partner CSOs. Environmental and health impacts may disproportionately affect populations located in close proximity to the mining sites. Therefore, it is important to select or consult with CSOs from communities where extractive industries are operating to better understand the local costs and benefits of natural resource management practices.

A description of the general potential impacts of the extractive industries is provided below.

General potential adverse impacts of extractive industries including uranium, gold, and oil:

In Niger, uranium and gold are mined in large open-pit mines using chemical ore refining processes. Gold may also be mined at small-scale, frequently using inefficient extraction processes. Niger has significant oil reserves, but most are not yet commercially exploited. The following, potentially significant, environmental impacts may result from extractive industry operations:

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Land Disturbance: Open pit mining activities can alter the landscape in ways that are potentially dangerous and costly. Excessive land clearing or steeply sloped mining pits may lead to landslides that destroy working sites, harm workers, or block waterways. Mining and oil operations may also cause large scale ecological disturbance through construction of infrastructure, land clearing, or explosions during seismic surveys. Land disturbance can harm wildlife and vegetation through habitat destruction, and may also lead to erosion which can negatively impact waterways, vegetation, and soil organisms.

Pollution:

Mining: Chemicals, such as cyanide, acids, solvents, and/or oils, are used in the ore refining process to separate valuable minerals from waste rock. These toxic processing chemicals may be released into the environment with resultant adverse impacts on water, soil, aquatic organisms, wildlife, waterfowl, and humans. The separation or leaching process, which may also extract heavy metals such as arsenic and/or radioactive elements, results in a waste solution (referred to as “tailings”), which are generally stored in large ponds or tailings dams. These dams may attract waterfowl and wildlife that suffer both acute and chronic poisoning as a result of direct contact with and ingestion of the contaminated solution. Leakage or overflow from tailings dams may also allow toxic constituents directly into the environment via surface water and groundwater flow. Releases and failures of tailings dams have been documented across the globe, and the majority of major mining-related environmental incidents worldwide have been the result of dam overtopping, breaching, geotechnical failure, or earthquake2.

Oil: Oil spills may result from corrosion of oil pipes, poor maintenance of infrastructure, leaks or human error, and at times are as a consequence of vandalism, theft of oil or sabotage. Drilling fluids, refinery effluents, and gas flares may also be sources of pollution from oil production. The effects of oil contamination on wildlife may be caused by either the physical nature of the oil (physical contamination and smothering), by its chemical components (toxic effects and accumulation), or indirectly by damage to critical habitats. Oil spills and waste dumping can kill wildlife and plants, but may also impair the ability of organisms to reproduce, causing long term harm to wildlife and plant populations. Oil spills may also contaminate surface water, groundwater and soil, potentially harming human health and natural-resource based livelihoods such as agriculture and fisheries.

Water: In addition to the potential for contamination of surface and groundwater discussed above, extremely large quantities of water are often necessary to support extractive industry operations. Water use for processing minerals and controlling dust can significantly deplete the groundwater table near large scale mines. This reduces the amount of water available for recharging wetlands and surface water bodies, thereby affecting organisms that depend on those waters. Decreasing water supplies can also lead to significant negative social and economic impacts, including reduced availability of potable drinking water and increasing competition for suitable agricultural land. In Niger, groundwater depletion near uranium mining operations has also been linked to negative impacts on nomadic populations and livestock, and an increased rate of desertification3. Finally, pollution from oil spills and mining wastes can severely degrade surface water and groundwater quality, potentially leading to adverse impacts on human health, wildlife and agricultural productivity.

Dust: Dust generated by metal mining can be harmful. Using wind to separate metal from ore, or using machinery that generates rock dust, can lead to silicosis. Silicosis is a disease caused by inhaling silicates in the dust of crushed rocks; it can severely decrease workers’ lung capacity and productivity, and it sometimes results in their deaths. Mining dusts generated through ore also contain heavy metals such as arsenic and lead. Mining dust may also deposit in surface water causing sedimentation and turbidity problems.

2 Akcil, A. (2006). Managing cyanide: health, safety and risk management practices at Turkey's Ovacik gold-silver mine. Journal of Cleaner Production, 14(8), 727-735.3 Greenpeace International. (2010). Left in the Dust: Areva’s Radioactive Legacy in the Desert Towns of Niger. Accessed March 3, 2012: http://www.greenpeace.org/international/Global/international/publications/nuclear/2010/AREVA_Niger_report.pdf

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Human Health: Waste rock, dust, and the byproducts of the ore refining process may all pose serious human health risks. In addition to the chemical byproducts of the refining process, uranium mining may also release radioactive elements into the environment. Exposure to radioactivity has been linked to genetic mutations, birth defects, cancer, leukemia and disorders of the reproductive, immune, cardiovascular and endocrine systems4. Ore may also be roasted during the refining process, releasing harmful chemicals into the air, potentially leading to respiratory health impacts. In addition to these impacts, extractive industry workers may also face serious occupational safety and health risks including collapse of structures or explosions.

Socio-economic impacts: Extractive industry operations are inherently finite and pose significant environmental risks to water, soil, wildlife, livestock, and vegetation. Therefore, inadequate planning for alternative livelihoods and remediation of environmental impacts may lead to significant adverse social and economic impacts. In addition, extractive industries often attract workers from outside the local community. Migration of workers and/or displacement of local populations may lead to social conflicts. Minerals and oil are extremely valuable resources and conflicts may also arise directly over the physical control of these resources.For more information on environmental risks in the extractive industries, see USAID’s ‘Partnering with Extractive Industries for the Conservation of Biodiversity in Africa: A Guide for USAID Engagement’ (http://pdf.usaid.gov/pdf_docs/PNADN726.pdf) and Chapter 4.5 (Small-Scale Mining) of USAID’s Environmental Guidelines for Small-scale Activities in Africa (www.encapafrica.org/egssaa.htm

Recommended Determinations

Intervention categories 1, 2&3 are generally aimed at the overall assessment of the capacity of legislature, CSOs, media, judiciary and industries relevant to programmatic activities, with respect to oversight of their respective representational functions. Implementation of these activities should generally have no significant adverse environmental impacts, and would as such, generally belong to classes of activities eligible for categorical exclusion.

However, in categories 4&5 where the oversight functions of the target organization have implications of environmental risks, a Negative Determination is recommended pursuant to 22 CFR 216.3(a) (2) (iii), subject to the following conditions:

Assessments shall examine the understanding of the target organization or legislature regarding the planning and oversight implications of the environmental risks in question, to appropriately inform capacity building, training, and technical assistance plans and activities.

Assessment of the target organization’s capacity to effectively develop and implement an EMMP to mitigate identified environmental risks.

Whenever an assessment is intended to materially inform or affect the selection of partner CSOs, the assessment shall address the CSO’s awareness of the environmental impacts of programmatic activities.

Assessments related to natural resource management activities are pursuant to 22 CFR 216.3(a) (2) (iii). A Negative Determination is recommended subject to the following conditions:

Assessments shall examine the understanding of the target organization or legislature regarding the planning and oversight implications of environmental risks in the extractive industries to appropriately inform capacity building, training, and technical assistance plans and activities.

The program shall select or consult with CSOs based locally in communities where extractive industries are operating, to better understand and promote engagement on local environmental and socio-economic issues (a minimum of one CSO). This condition applies only to the extent that such

4 See U.S. Environmental Protection Agency: http://www.epa.gov/rpdweb00/understand/health_effects.html

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

http://pdf.usaid.gov/pdf_docs/PNADN726.pdf

locally-based CSOs exist and are appropriately qualified partners based on assessment outcomes and other applicable criteria.

Whenever an assessment is intended to materially inform or affect the selection of partner CSOs, the assessment shall address the CSO’s awareness of the environmental impacts of the extractive industries.

3.2 Training and Capacity Building in the fields of Peace, Democratic Governance, Counter Extremism,

rule of law, legislation enactment/strengthening, administration of justice and training of teachers.

Illustrative activities under this intervention category include the following;

Conflict resolution and mitigation training

Training for election observers

Support for voter register/logistics

Consensus and trust building forums and events

Training, capacity building and technical assistance for governments, judiciary, members of parliament, police, civil society organizations and the media to improve transparency, good governance and administration of justice.

Capacity building and technical assistance for electoral commissions to organize local, district and general level elections

Training local governments officials to improve transparency and good governance at local and district levels

Institutional assistance to political parties

Policy support to improve political party funding

Technical assistance for legislature for rule of law

Training and capacity building for peace building civil society organization in West Africa

Training legislature in anti-corruption practices and rule of law

General capacity building for CSOs including training in budget management, staff and recruitment and proposal writing

Problem solving workshops to promote social cohesion and peaceful elections.

Capacity building, training, and technical assistance for members of parliament and CSOs to enhance their understanding of the extractive industries.

Site visits and town hall meetings to enhance understanding of extractive industry operations and local concerns.

Establishment of cross-party Women’s Legislative Network and associated technical assistance, including enhancing understanding of the impacts of natural resource management practices.

Training, capacity building and technical assistance support for teachers. Training and capacity building curriculum related to equipment handling and disposal including military equipment in cases of disarmament /demobilization.

Distribution of equipment or ICT materials to CSO’s, media, schools, parliament, judiciary, election infrastructure etc. as part of technical assistance and capacity building activities.

Potential Adverse Impacts and Considerations Regarding Recommended Determinations

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This intervention category is generally aimed at strengthening the capacity of governments, civil society organizations (CSO’s), political parties, media and the general public to promote peaceful coexistence, rule of law, transparency, human rights, democratic governance and free and fair elections. Implementations of these activities generally have no foreseeable significant adverse environmental impacts, and as such may belong to classes of activities eligible for categorical exclusion.

However, in cases where training, capacity building or technical assistance functions have implications of environmental risks, a Negative Determination is recommended pursuant to 22 CFR 216.3(a) (2) (iii), subject to the conditions outlined in the table of activities below:

Activity Determination and Conditions

1. General organizational and legislative capacity building for CSOs, parliamentary staff, judiciary and court staff

A Categorical Exclusion is recommended per;

22 CFR 216.2 (C) (i), education, technical assistance or training programs except to the extent such programs include activities directly affecting the environment.

2. Capacity building, training, and technical assistance (for members of parliament, CSOs, Judiciary, court staff, media groups, teachers etc.) related to issues directly effecting the environment

3. Training and capacity building curriculum related to equipment (mainly small tools, office equipment, school equipment etc) handling or disposal.

A Negative Determination is recommended pursuant to 22 CFR 216.3(a) (2) (iii), subject to the following conditions:

Training, technical assistance, and capacity building activities shall emphasize and fully integrate information on the environmental risks associated with the training topic, where applicable. For example, with thematic topics like land tenure, extractive industries, public procurement, disarmament, equipment acquisition, forestry, fisheries, etc. Best management practices to mitigate environmental risks in these areas, including cleaner production5 strategies must be emphasized. Risks and best practices outlined in USAID’s Partnering with Extractive Industries for the Conservation of Biodiversity in Africa: A Guide for USAID Engagement http://pdf.usaid.gov/pdf_docs/PNADN726.pdf and guidance on cleaner production contained in Part III (Micro and Small Enterprises – Chapters 1,2,3, & 4.5) of USAID’s Environmental Guidelines for Small-scale Activities in Africa (www.encapafrica.org/egssaa.htm) must be followed, where applicable

Training, technical assistance, and capacity building in subjects related to general equipment acquisition and disposal or public procurement etc. shall further comply with equipment packaging and disposal guidelines provided in USAID Environmental Guidelines for Small -Scale Activities in Africa (EGSSAA), 2nd Edition, Chapter 15: Solid Waste: Generation, Handling, Treatment and Disposal (http://www.encapafrica.org/EGSSAA/Word_English/solidwaste.doc).

In cases where the IP is to engage in direct distribution of equipment or

5 Cleaner production is a preventive business strategy designed to conserve resources, mitigate risks to humans and the environment, and promote greater overall efficiency through improved production techniques and technologies. In addition to environmental, health and safety benefits, many cleaner production techniques provide opportunities to substantially reduce operating costs and improve product quality. Cleaner production methods may include: substituting different materials, modifying processes, upgrading equipment, and/or redesigning products.

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http://www.encapafrica.org/EGSSAA/Word_English/solidwaste.doc




4. Distribution of equipment or ICT materials to CSO’s, media, schools, parliament, judiciary, election infrastructure etc. as part of technical assistance and capacity building activities.

5. Training, capacity building and technical assistance related to fisheries and forestry activities.

6. Site visits and town hall meetings to enhance understanding of extractive industry operations and local concerns

7. Establishment of a cross-party Women’s Legislative Network and associated technical assistance, including enhancing understanding of the impacts of Natural Resource Management practices.

ICT materials to CSOs, media, parliament, judiciary, schools, election infrastructure, etc. the IP shall conduct such activities in compliance with the guidelines in Chapter 15 of the EGSSAA. An Equipment Management Plan (EMP) to this effect shall be developed by the IP. The EMP must detail appropriate packaging, handling, storage and disposal methods for each category of equipment being distributed. Particular attention must be paid to illustrating safe disposal of hazardous waste. The IP shall be responsible for ensuring copies of the EMP accompany all equipment distribution to respective recipients.

The EMP must be approved by the MEO prior to initiation of these activities.

Training, capacity building, and technical assistance related to fisheries or forestry shall comply with guidelines provided in the USAID Environmental Guidelines for Small -Scale Activities in Africa (EGSSAA), 2nd Edition, Chapter 6 and Chapter 7 respectively (http://www.encapafrica.org/EGSSAA/Word English).

Information on environmental risks and best management practices in the extractive industries consistent with USAID’s Partnering with Extractive Industries for the Conservation of Biodiversity in Africa: A Guide for USAID Engagement http://pdf.usaid.gov/pdf_docs/PNADN726.pdf and Part III (Micro and Small Enterprises – Chapters 1,2,3, & 4.5) of USAID’s Environmental Guidelines for Small-scale Activities in Africa (www.encapafrica.org/egssaa.htm), should be emphasized during site visits, and available during briefings for citizens and organizations prior to town hall meetings.

3.3 Small Scale Construction and Rehabilitation Activities

Activities in this intervention category are intended to provide enabling infrastructure to support livelihoods, improve access to social services or support civic education. No envisioned construction and rehabilitation works are expected to be of large- scale. They may be implemented across the region, but are particularly

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likely to be focused in Burkina Faso, Chad, Mauritania, Cote d’Ivoire and Niger. Illustrative activities include the following;

Construction and rehabilitation of community protected water sources (including spring and shallow wells)

Rehabilitation of existing boreholes

Construction of water storage and delivery systems for humans and livestock

Latrine construction

Construction of rainwater collection systems and/or irrigation channels in support of agricultural activities

Construction of new community radio stations

Rehabilitation of existing radio stations

Rehabilitation of existing community radio stations

Construction of individual markets or transport yards

Construction/rehabilitation of community centers and market stalls

Construction/rehabilitation of court houses.

Rehabilitation of existing social service infrastructure including schools and clinics

Windbreaks, greenbelts and dune stabilization

Community based water user associations organized/re-organized

Training and capacity building in water systems operation and management


Activities in this intervention category relates to small scale infrastructural development. These include; construction and rehabilitation of water, irrigation and sanitation infrastructure, construction and rehabilitation of latrines, clinics, market yards, schools, radio stations, windbreaks and dune stabilization. The potential adverse environmental impacts of small scale construction activities outlined below.

In the absence of complicating factors6 USAID AFR has concluded that general construction involving a total disturbed area of less than 10000m2 is of its nature unlikely to create any significant adverse impacts of any kind (Dams and diversions are not considered general construction). Medium scale construction or small scale in the presence of complicating factors presents the risks outlined in section 3.3.

Activities involving organization or re-organization of community water-user association groups present no foreseeable risk of adverse significant impacts. However, depending on the precise final specification of these activities, they may or may not be eligible for categorical exclusion.

Training and capacity building in water systems operation and maintenance are intended to make infrastructural investments more sustainable and thus do not present any foreseeable risks of environmental impacts. However, training and capacity building curriculum must address the issue of water quality assurance.

General Potential Adverse Impacts Resulting from Construction Activities

6 Complicating factors include for e.g. sitting within 30m of a permanent or seasonal stream or water body or displacement of existing settlements or inhabitants, or building on an average slope in excess of 15%, or building on a site that is heavily forested or in otherwise in undisturbed local ecosystem

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The environmental impacts of the general construction and operation of these activities are widely known. These are summarized below.

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, compacting and leveling can disrupt local drainage.

Erosion and Sedimentation/fouling of surface and ground water. 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. In the case of dam construction or rehabilitation, where construction is within the stream or riverbed, such risks are particularly acute.

Surface and groundwater contamination; the use of toxic fuels, oils and other chemicals during construction has the potential of contaminating both surface and groundwater if not handled properly. Inadequate or poorly managed sanitation facilities for construction crews can also contaminate surface and groundwater. Runoff can also lead to gullying on adjacent lands; on the site itself, erosion can result in permanent degradation of the site.

Standing 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 much of West Africa.

Adverse social effects: the influx of migrant workers for the purpose of construction into the local area may lead to the spread of diseases such as HIV/AIDS and other sexually transmitted diseases. Local residents may also be displaced as a result of construction. Dust and noise often associated with construction may also cause nuisance to the local residents, disrupt schools, and pose an active health threat to the most vulnerable members of the population. Experience shows that these impacts are controllable below the level of significance with basic good construction management practices.

Adverse impacts of materials sourcing. Construction requires a set of materials often procured locally: timber, fill, sand and gravel, bricks. 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). While IPs generally have direct control over their general contractors (GCs), construction materials are often procured by GCs from sub-vendors. In the case of timber, these sub-vendors are often the terminus of a long and untraceable supply chain. This separation from source both limits the actions that IPs can take to assure environmentally responsible sourcing of these materials and reduces IP responsibility for these impacts. (It should also be noted that for the relatively small construction projects anticipated under the ATB portfolio, adverse impacts related to materials sourcing should be quite limited. However, IPs can and should undertake reasonable due diligence to assure that they do not bear direct responsibility for adverse impacts, and to reduce indirect impacts so far as feasible.

Operation of constructed facilities

General compounds including offices and radio stations have significant potential environmental and health impacts associated with their operation: In operation, these facilities generate significant quantities of wastewater and both human 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

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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.

Small Dams and irrigation schemes present a number of distinct environmental risks. Stagnant water behind dams can create breeding habitat for disease vectors. Dams raise local groundwater levels (which, while sometimes a desired objective, can lead to increased contamination of groundwater). Excess abstraction 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 on soil quality (e.g. salination); they also pose a high risk of contaminating shallow groundwater and downstream surface waters with agricultural chemicals. Experience shows that these impacts can be controlled with a combination of siting, design and operating practices.


Pursuant to the discussions above, a Negative Determination with conditions, per 22 CFR 216.3(a) (2) (iii) is recommended for activities under this intervention category subject to the following conditions:

Small Scale Construction and Rehabilitation Activities

Activity Conditions

1.Construction and rehabilitation of community protected water supplies

2.Rehabilitation of existing boreholes

3.Construction of water storage facilities

4. Construction or rehabilitation of water points for Livestock

1. Good practice design standards generally consistent with USAID’s Environmental Guidelines for Small Scale Activities (water supply and sanitation chapter) www.encpafrica.org/egsaa.htm must be implemented for both new construction and rehabilitation works. These standards must be specified in the EMMP and must include siting of new wells away from groundwater contamination sources, exclusion of livestock from water points (with respect to water intended for human consumption), and prevention of standing water at water supply points.

2. Water quality assurance plan must be developed and implemented by IP. This plan must ensure that all new and rehabilitated USAID-funded water supplies provide safe drinking water, defined as meeting both 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 will occur.

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. Specifically, the USAID managing team must assure that the standards and testing procedures described in “Guidelines for Determining the Arsenic Content of Ground Water in USAID Sponsored Well Programs in Sub-Saharan Africa”(www.encapafrica.org/docs.htm#specificwater). Note that this guidance requires initial testing, and quarterly testing for four quarters. If the program terminates in

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http://www.encpafrica.org/egsaa.htm

Activity Conditions

less than four quarters, remaining testing is the responsibility of the mission. Water Violating the 10ppb Arsenic standard may not be supplied for public consumption.

3. Monitoring for & response to overdraw. Wells used for irrigation must be monitored for groundwater overdraws. In the event that overdraws occurs; draw from the well must be reduced to a sustainable level.

5.Latrine construction

6. Construction of rainwater collection systems and or irrigation channels in support of agricultural activities

7. Other small scale construction

1.Construction will be undertaken in a manner generally consistent with the guidance for environmentally sound construction, provided in the Small Scale Construction chapter of the USAID Environmental Guidelines for Small-scale Activities in Africa (www.encapafrica.org/egssaa.htm) At minimum, (1) 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.); (2) Construction must be managed so that no standing water on the site persists more than 4 days; (3) 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; (4) IPs must identify and implement any feasible measures to increase the probability that timber is procured from legal, well-managed sources.

2. The formal AFR subproject/sub grant review process, as set out by the AFR Environmental Review Form (available at www.encapafrica.org/compliance.htm) must be completed and approved prior to construction or rehabilitation of each site/system.

3. General consistency with EGSSAA. The environmental management conditions established by the ERF process must be generally consistent with good-practice guidance of USAID’s Environmental Guidelines for Small-Scale Activities in Africa (agriculture and irrigation chapters, construction chapters;www.encapafrica.org/egssaa.htm).

4. The IP must assure implementation of any mitigation and monitoring conditions specified by the approved ERF.

8. Construction of new community radio stations

Station design. All stations must include/conform to the following design elements. Where existing stations do not include these elements, corrective action must be taken within 6 months of the effective date of this IEE to provide them

Latrine/septic tank design prevents in-out access for insects or other disease vectors from the pit or holding tank

Latrines are accompanied by hand washing stations All sources of gray water (kitchen sinks and hand wash stations)

discharge to either a seepage pit or sump at least 15m from any source of groundwater or surface water tapped for domestic use, or to an impermeable pump-out tank

Latrines or the terminus of any septic leach field must be at least 30m from any source of shallow groundwater or surface water tapped for

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


Activity Conditions

domestic use or discharge to an impermeable pump-out tank Sitting, grading and/or drainage structures prevent runoff from the

compound from creating standing water on the compound or adjacent land during rainy season

Septic pump-out point, if any, shall feature a concrete and drain with return to the septic

Construction management. The ERF process must impose the following construction management requirements: (1) 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); (2) Construction must be managed so that no standing water on the site persists more than 4 days; (3) 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; (4) IPs must identify and implement any feasible measures to increase the probability that timber is procured from legal, well-managed sources.

Station and compound operation. IP’s shall assure that Latrine shall be maintained in clean and orderly condition, including

intact screens on the septic vent stacks (if applicable) and tight-fitting seals on pump-out points

Drainage structures shall be kept free of obstruction and otherwise maintained in sound condition

Solid waste being held for collection or transport to dump site shall be stored in sealed containers

The compound shall be maintained free of litter and debris

9. Rehabilitation of existing community radio stations

10. Construction and rehabilitation activities (for e.g. individual markets, transport yards, court houses , community centers, schools, clinics etc)

1. The formal AFR subproject/sub grant review process, as set out by the AFR Environmental Review Form (available at www.encapafrica.org/compliance.htm) must be completed and approved prior to construction or rehabilitation of community radio station

2. Construction management. The ERF process must impose the following construction management requirements: (1) 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); (2) Construction must be managed so that no standing water on the site persists more than 4 days; (3) 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; (4) IPs must identify and implement any feasible measures to increase the probability that timber is procured from legal, well-managed sources.

3. The design must provide for drainage, sanitation and fresh-water and the activity must include development of a practical environmental management protocol for the facility (e.g., cleaning, disposal of waste, maintenance of latrines, etc.). The IP must work with the responsible local stakeholders or administration to implement this protocol and maximize the probability that it will continue to be

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

Activity Conditions

implemented after project hand-off.

4. The IP must assure implementation of any mitigation and monitoring conditions specified by the approved ERF.

11. Community based water-user associations organized/re-organized

12.Windbreaks, greenbelts and dune stabilization

1.Negative Determination (no condition)

13. Training and capacity building in water systems operation and management

1.Training and capacity building address water quality assurance, including (but not limited to) maintenance of drainage and livestock exclusions

3.4 Livelihood support, training and capacity building in vocational activities

Activities under this intervention category are intended to build the skill set and capacity of local residents particularly the youth to acquire vocational skills to engage in small scale income generating activities. These activities will provide alternative livelihood support for the youth who in many instances are used as tools for extremism, terrorism and rebel acts. Illustrative activities will include the following;

1. General business management capacity-building, support for producer associations and marketing, including provision of market information

2. Technical assistance and training in artisanal activities including but not limited to jewelry, clothing, household items, carpentry etc.

3. Provision of tools and other equipment in support of livelihood activities such as grinding mills.

4. Technical assistance and training in forestry or fisheries activities related to livelihood support.


Activity 1 focus on building the general business management capability of entrepreneurs and micro enterprises and small businesses in book/record keeping and financial management. It will also include providing up to date and accurate information on market value of commodities and linking

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producers/entrepreneurs to potential buyers. This activity is not anticipated to result in any significant adverse environment impact.

Training and technical assistance have no significant adverse environmental impacts. However, if the training or technical assistance activity could lead to exploitation of resources to produce a finish product, then issues of over exploitation of resource, waste generation and occupational health and safety (artisanal/craftsmanship) could adversely impact both the natural and physical environments.

Providing tools and equipment in support of other livelihood activities such as grinding or milling could adversely impact on the environment during operation of such a facility. Solid and liquid waste generation as a result of milling or grinding activities could affect the physical environment if not handled properly. Improper handling of the equipment could also result in injuries to human health during operation.

Provision of fuel efficient cooking equipment and stoves is intended to discourage the use of timber and firewood for cooking thus conserving the natural resource base. Technical assistance in the operation and use of such a facility should address issues of occupational health and safety measures.

Recommended DeterminationsIn pursuant to the discussions above, the following threshold determinations are recommended:

Activity Conditions

1.General business management capacity building, support for producer associations and provision of market information

A Categorical Exclusion is recommended per;

22 CFR 216.2 (C) (i), education, technical assistance or training programs except to the extent such programs include activities directly affecting the environment (such as construction)

2. Technical assistance and training in artisanal activities (e.g. carpentry, jewelry, clothing etc.)

Negative Determination subject to the following conditions

1.Training curriculum must address: - Best practice measures in handling and managing waste - Occupational health and safety measures at the workplace

2. Compliance with national/local policies (if any exist) on resource exploitation OR IP’s must ensure that resource use are from well managed and sustainable resource base.

3.Provision of tools and equipment in support of livelihood activities

Negative Determination subject to the following conditions

1. Technical assistance in handling of grinding and milling equipment must

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address proper waste management and handling practices.

2. Issues of occupational health and safety at the workplace

4. Technical assistance and training related to livelihood support in the fields of fisheries or forestry.

Training and technical assistance related to fisheries or forestry shall comply with guidelines provided in the USAID Environmental Guidelines for Small -Scale Activities in Africa (EGSSAA), 2nd Edition, Chapter 6 and Chapter 7 respectively (http://www.encapafrica.org/EGSSAA/Word English).

3.5 Waste/Refuse Clearance, Collection, Disposal and Drainage Clearance

Illustrative activities under this intervention category include the following:

1. General waste or refuse clearance, removal and disposal.

2. Providing at risk youth with opportunities to improve their socio-economic conditions through community clean up exercises and being paid a small fee.

3. CSOs will distribute garbage cans, wheelbarrows and other equipment to at risk youth to collect garbage in their communities.

4. At risk youth will be trained to lead sustainable health campaigns to raise awareness about hygienic standards in their communities.

5. Clearing, collecting and disposing off garbage and heavily compacted earth in drainages.

Potential adverse environmental impacts from Solid Waste activities

The typical municipal solid waste stream will contain general wastes (organics and recyclables), special wastes (household hazardous, medical, and industrial waste), and construction and demolition debris. Improper waste management activities can:

Increase disease transmission or otherwise threaten public health. Rotting organic materials pose great public health risks, including, as mentioned above, serving as breeding grounds for disease vectors such as rats and flies. Waste handlers and waste pickers are especially vulnerable and may also become vectors, contracting and transmitting diseases when human or animal excreta or medical wastes are in the waste stream. (See the discussion on medical wastes below and the separate report on “Healthcare Waste: Generation, Handling, Treatment, and Disposal” in this series.) Risks of poisoning, cancer, birth defects, and other ailments are also high.

• Contaminate ground and surface water. Municipal solid waste streams can bleed toxic materials and pathogenic organisms into the leachate of dumps and landfills. (Leachate is the liquid discharge of dumps and landfills; it is composed of rotted organic waste, liquid wastes, infiltrated rainwater and extracts of soluble material.) If the landfill is unlined, depending on the drainage system and the composition of the underlying soils, this runoff can contaminate ground or surface water. When leachate from sanitary landfills is discharged into surface water it will similarly contaminate these bodies. Many toxic materials, once placed in the general solid waste stream, can only be treated or removed with expensive advanced technologies. Currently, these are generally not feasible in most parts of Africa, Asia, and Latin America and the Caribbean. Even after organic and biological elements are treated, the final product remains harmful.

• Create greenhouse gas emissions and other air pollutants. When organic wastes are disposed of in deep dumps or landfills, they undergo anaerobic degradation and become significant sources of methane, a gas with 21 times the effect of carbon dioxide in trapping heat in the atmosphere (see “Climate Change” section below). Garbage is often burned in residential areas and in landfills to reduce volume and uncover metals.

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Burning creates thick smoke that contains carbon monoxide, soot and nitrogen oxides, all of which are hazardous to human health and degrade urban air quality. In addition, combustion of polyvinyl chlorides (PVCs) generates highly carcinogenic dioxins.

• Damage ecosystems. When solid waste is dumped into rivers or streams it can alter aquatic habitats and harm native plants and animals. The high nutrient content in organic wastes can deplete dissolved oxygen in water bodies, denying oxygen to fish and other aquatic life forms. Solids can cause sedimentation and change stream flow and bottom or benthic habitat. Siting dumps or landfills in sensitive ecosystems may destroy or significantly damage these valuable natural resources and the services they provide.

• Injure people and property. In locations where shantytowns or slums exist near open dumps or near badly designed or operated landfills, landslides or fires can destroy homes and injure or kill residents. The accumulation of waste along streets may present physical hazards, clog drains and cause localized flooding.


Negative Determination is recommended for activities in this intervention category per 22 CFR 216.3(a) (2) (iii) subject to the following conditions:

Activity Conditions

1. General Waste/Refuse clearance, removal, and disposal.

Training, technical assistance and capacity building in waste collection and disposal activities.

Good and integrated waste management standards generally consistent with USAID’s sector guidelines on solid waste found at http://www.usaidgems.org/Sectors/solidWaste.htm must be followed. These standards must be specified in the EMMP and must consider all types of waste and all facets of the waste management processes. These standards must ensure that:

Protective wear and the correct equipment are used in waste clearance, removal, collection and disposal activities.

Waste separation at the source and resource recovery where possible. Managing non-hazardous and special or hazardous wastes separately. Collecting and transporting all waste effectively and efficiently. Disposing off waste at appropriate designated disposal sites: including

landfills, incinerators, and recognized legal sites for hazardous, medical, automotive and construction/demolition waste.

Where applicable, Community Based Management of Solid Waste standards must also be incorporated (http://www.encapafrica.org). This shall ensure all forms of local involvement including:

Raising awareness and teaching proper sanitation behavior. Involving the community in setting service or payment charges. And ensuring participation, consultation, administration, and/or

management functions.

Best practice measures in handling and managing solid waste as per

http://www.usaidgems.org/Sectors/solidWaste.htm should be followed

General occupational health and safety measures. Compliance with national/local policies (if any exist) on collecting and

disposing off waste.

Drainage Clearance Negative Determination subject to the following conditions:

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http://www.usaidgems.org/Sectors/solidWaste.htm


- Removal and disposal of garbage and heavily compacted earth from drainages shall also comply with USAID sector guidelines on solid waste found at


3.6 Activities/sub-grants for livestock distribution and sub-grant activities related to fisheries or forestry. This includes delivering training, capacity building or technical assistance in these fields.


1. Distribution of livestock including cattle, goat, sheep, chicken etc. as part of small grant activities and a vital component in improving rural livelihoods.

2. Training and technical assistance given to recipients of livestock to ensure best practice and adherence to livestock production standards.

3. General support to rural households in animal husbandry activities.

4. Sub-grant activities related to fisheries or forestry.

Pursuant to the above and 22 CFR 216.3(a) (2) (iii), a Negative Determination is recommended for activities in this intervention category, subject to the following condition:


1. Distribution of livestock, e.g. goats, chicken, cattle, sheep etc as part of small grants activities


Distribution of all livestock as part of small grant program activities shall comply with environmental mitigation risk, information and best management guidelines provided in the USAID’s Environmental sector

guidelines found at http://www.usaidgems.org/Sectors/livestock.htm Guidelines adopted for livestock activities must be specified in the EMMP.

2. Training, capacity building and technical assistance in livestock production

Training, capacity building, and technical assistance pertaining to livestock curriculum shall comply with best management guidelines and information provided in USAID’s Environmental sector guidelines found at

http://www.usaidgems.org/Sectors/livestock.htm

3. Sub-grant activities related to fisheries or forestry.

Training and technical assistance related to fisheries or forestry shall comply with guidelines provided in the USAID Environmental Guidelines for Small -Scale Activities in Africa (EGSSAA), 2nd Edition, Chapter 6 and Chapter 7 respectively (http://www.encapafrica.org/EGSSAA/Word English).

3.7 Activities/sub-grants to increase communication and collaboration between CSOs and legislature on enactment of legislation related to natural resource management.


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1. Joint MP-CSO policy briefings on natural resources and the Extractive Industries Transparency Initiative (EITI) process.

2. Public hearing on the EITI process.

3. Creation of a Citizens Office in the National Assembly.

4. Creation of a directory of extractive industry experts


ACTIVITY TYPE POTENTIAL ADVERSE IMPACTS

1. Joint MP-CSO policy briefings on natural resources and the EITI process

This activity includes a series of policy briefings by regional and national experts and academics for MPs and CSOs to increase their fact-based knowledge of the extractive industry and the EITI process, and provide comparative examples of how natural resources and managed in other countries. This activity conforms to a class of activities that may be eligible for categorical exclusion.

However, the extractive industries have potential, perhaps significant, adverse impacts on critical environmental resources and human health (as articulated in this IEE). Lack of access to sound technical expertise on environmental risks and best management environmental practices used in the extractive industries on the part of MPs and CSOs may result in environmental issues being given inadequate attention in future oversight of NRM practices.

2. Public hearing on the EITI process

This activity is intended to enhance the understanding of the public and on the EITI process, and offer MPs and CSOs an opportunity to apply knowledge and skills acquired during the program. This activity conforms to classes of interventions eligible for Categorical Exclusion.

Implementation of a public hearing on the EITI process has no foreseeable significant adverse environmental impacts, whether direct or indirect. This activity belongs to classes of activities eligible for categorical exclusion pursuant to 22 CFR 216.2 (C) (iii) Analyses, studies, academic or research workshops and meetings.

3. Creation of a Citizen’s Office in the National Assembly

This activity is intended to increase issue-based interaction between citizens and MPs through the creation of a Citizen’s Office on the premises of the National Assembly where MPs and parliamentary staff could meet with citizens and answer questions on specific legislative topics.

This activity has no foreseeable significant adverse environmental impacts, whether direct or indirect.

4. Directory of Extractive Industry Experts

This activity aims to create a reference document allowing MPs to easily identify and seek input from relevant extractive industry technical experts, civic organizations, and resources.

Given that NRM activities have potential, perhaps significant, adverse impacts on critical environmental resources and human health (as articulated in this IEE), it is important that decision-makers have access to technical expertise on environmental issues related to the extractive industries. Lack of access to technical input and expertise on the

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environmental risks of the extractive industries may result in environmental issues being given inadequate attention in future oversight of NRM practices.


Pursuant to the above analysis, the following threshold determinations, and conditions where applicable, are recommended for the activities in this intervention category:


1. Joint MP-CSO policy briefings on natural resources and the EITI process


At least one policy briefing in the series shall include regional and/or national technical experts or academics with expertise in the environmental impacts and best management practices in the extractive sector.

2. Public hearing on the Extractive Industries Transparency Initiative (EITI) process

A Categorical Exclusion is recommended per:

22 CFR 216.2 (C) (iii) Analyses, studies, academic or research workshops and meetings

3. Creation of a Citizen’s Office in the National Assembly

A Categorical Exclusion is recommended per:

22 CFR 216.2 (C) (i), education, technical assistance or training programs except to the extent such programs include activities directly affecting the environment.

4. Directory of Extractive Industry Experts

A categorical exclusion pursuant to 22CFR216.2(c)(2)(v) document and information transfer

3.8. Activities/sub-grants with media organizations to increase timely and transparent information updates on the extractives sector.

Activities under this intervention category are intended to increase transparent and timely information regarding the extractive industries, and to advance the media’s role as a catalyst for bolstering citizen awareness and engagement in the management of their natural resources. Illustrative activities include subgrants to media organizations to provide training of specialized journalists to cover extractive industry issues.


The activities in this intervention category have no direct adverse environmental impacts. However, the objective of the activities is to increase transparency and citizen awareness about the extractive industries – which are industries that have potential, perhaps significant, adverse environmental, social and human health impacts (as articulated in this IEE). Therefore, it is prudent to ensure that any discussions and activities around transparency address not only financial transparency, but also transparency regarding the

environmental and social dimensions of the extractives sector.

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Pursuant to the analysis above and 22 CFR 216.3(a) (2) (iii), a Negative Determination is recommended for activities in this intervention category, subject to the following condition:

Activities shall address transparency with respect to environmental and social issues in the extractive industry, in addition to financial transparency. For example, a portion of information updates may address recent environmental or occupational health studies undertaken by mining or oil companies, or corporate social responsibility policies and reports. If training is provided for journalists to cover specialized issues in the sector, environmental and social issues shall be adequately addressed.

3.9 Small Grant ActivitiesVarious projects and programs in the Peace and Governance portfolio will take advantage of small grants programs as a tool to expand their impact. The range of activities for which grants may be used are yet to be determined. However, these activities will be within, but not limited to the scope of activities set out in sections 3.3, 3.6, 3.7 and 3.8 of this IEE. As such, the analysis set out in this section already examines the environmental impacts of activities to be supported with sub grants, and sets out recommended determinations and conditions. This analysis applies equally whether the activities are to be conducted directly by a prime contractor/grantee, or via a sub grant mechanism. The general conditions of section 4, below, require that IPs impose these applicable IEE conditions on their sub grantees, require reporting on these conditions, and monitor their performance. Thus, no separate recommended determinations are necessary or appropriate for sub-grant activities.

3.10 Deferral: Training and capacity building curriculum related to handling or disposal of military equipment and training related to disarmament /demobilization.

It is possible that USAID/WA will be requested to provide training and capacity building related to the issue of handling or disposal of military equipment and training related to disbarment / demobilization over the life time of this IEE. USAID does not at present have environmental guidelines on this topic. As a consequence USAID/WA will defer commencement of any such activities pending approval of an amended IEE that includes appropriate guidelines, based on either international best practices, or on new guidance to be developed by USAID.

4.0 General Project Implementation and Monitoring Requirements

In addition to the specific conditions enumerated in Section 3, 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 Regional Peace and Governance Office (RPGO) team shall provide each RPGO Implementing Partner (hereinafter IP), with a copy of this IEE; each IP shall be briefed on their environmental compliance responsibilities by their cognizant C/AOR. During this briefing, the IEE conditions applicable to the IP’s activities will be identified.

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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/AOTR 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 grant 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: Sample EMMP formats are available at www.encapafrica.org/meoEntry.htm.)

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 RPGO team shall assure that any future contracts or agreements for implementation of the project, 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.

6. RPGO Team monitoring responsibility. As required by ADS 204.5.4, the RPGO team will actively monitor and evaluate whether the conditions of this IEE are being implemented effectively and whether there are new or unforeseen consequences arising during implementation that were not identified and reviewed in this IEE. If new or unforeseen consequences arise during implementation, the team will suspend the activity and initiate appropriate, further review in accordance with 22 CFR 216. USAID Monitoring shall include regular site visits.

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 any IP adds new activities or makes substantial modifications to existing activities, an amendment to this IEE addressing these activities shall be prepared for USAID review and approval. No such new activities shall be undertaken prior to formal approval of this amendment.

Any ongoing activities found to be outside the scope of the approved Regulation 216 environmental documentation shall be halted until an amendment to the documentation is submitted and written approval is received from USAID.

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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.

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