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INITIAL ENVIRONMENTAL EXAMINATION PROJECT/ACTIVITY DATA Project/Activity Name: Conservation of Boma – Bandingilo Landscape Geographic Location(s) (Country/Region): South Sudan, East Africa Amendment (Yes/No), if Yes indicate # (1, 2...): NO Implementation Start/End Date (FY or M/D/Y): October 01,2018 to September 30, 2021 If Amended, specify New End Date: Solicitation Number: 720668-18-RFA-00001 Implementing Partner(s): TBD Bureau Tracking ID: South Sudan Conservation Boma-Bandigilo Landscape IEE_882018 https://ecd.usaid.gov/document.php? doc_id=51139 Tracking ID of Related RCE/IEE (if any): Conservation of Biodiversity across the Boma-Jonglei landscape in South Sudan https://ecd.usaid.gov/document.php? doc_id=44661 Tracking ID of Other, Related Analyses: ORGANIZATIONAL/ADMINISTRATIVE DATA Implementing Operating Unit(s): (e.g. Mission or Bureau or Office) USAID South Sudan Other Affected Operating Unit(s): Lead BEO Bureau: AFR Funding Account(s) (if available): Original Funding Amount: $ 7.5 Million If Amended, specify funding amount: If Amended, specify new funding total: Prepared by: Emmanuel Dijango, USAID/South Sudan and Josh Habib, GEMS/Cadmus Date Prepared: July 2018 Date Submitted to BEO 3 Aug. 2018 USAID/SOUTH SUDAN BOMA BANDINGILO IEE USAID 216 IEE, JULY 2018 1

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Page 1: Project/Activity Data - United States Agency for … · Web view(For example, clearance of natural forest for tree lots, non-sustainable harvesting levels of non-timber forest products,

INITIAL ENVIRONMENTAL EXAMINATIONPROJECT/ACTIVITY DATA

Project/Activity Name: Conservation of Boma – Bandingilo LandscapeGeographic Location(s) (Country/Region): South Sudan, East AfricaAmendment (Yes/No), if Yes indicate # (1, 2...):

NO

Implementation Start/End Date (FY or M/D/Y):

October 01,2018 to September 30, 2021

If Amended, specify New End Date:Solicitation Number: 720668-18-RFA-00001Implementing Partner(s): TBDBureau Tracking ID: South Sudan Conservation Boma-Bandigilo

Landscape IEE_882018https://ecd.usaid.gov/document.php?doc_id=51139

Tracking ID of Related RCE/IEE (if any): Conservation of Biodiversity across the Boma-Jonglei landscape in South Sudan https://ecd.usaid.gov/document.php?doc_id=44661

Tracking ID of Other, Related Analyses:

ORGANIZATIONAL/ADMINISTRATIVE DATA

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

USAID South Sudan

Other Affected Operating Unit(s): Lead BEO Bureau: AFRFunding Account(s) (if available):Original Funding Amount: $ 7.5 Million If Amended, specify funding amount: If Amended, specify new funding total:Prepared by: Emmanuel Dijango, USAID/South Sudan and Josh

Habib, GEMS/CadmusDate Prepared: July 2018Date Submitted to BEO 3 Aug. 2018

ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: X Environmental Examination

Deferral

Environmental Determination(s): X Categorical Exclusion(s)X Negative Determ w Conditions

Positive Deferred (per

22CFR216.3(a)(7)(iv)

IEE Expiration Date (if different from implementation end date):

September 30, 2021

Additional Analyses/Reporting Required:Climate Risks Identified: Low ___X___ Moderate ___X___ High ______

See Table 2.6. Climate Risk ManagementClimate Risks Addressed: Low ______ Moderate ___X___ High ______

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THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS

PROJECT/ACTIVITY SUMMARY

The purpose of this Activity is to build resilient communities and livelihoods and secure wildlife and biodiversity resources in the Boma-Bandingilo Landscape. This Activity directly contributes to the USAID South Sudan Integrated Essential Services Project whose purpose is to increase the resilience of individuals, households, and communities to absorb, adapt to, and recover from shocks.

The key outcomes sought through this Activity are resilient communities and livelihoods as well as secure wildlife and biodiversity habitats. Activity actions and investments will be expected to result in:

1. Increased capacity, plans and systems in place to sustainably manage land and natural resources and mitigate conflict in the Boma and Bandingilo parks and communities in the wildlife migratory corridor.

2. Secure wildlife and biodiversity within the Boma-Bandingilo Landscape.3. Increased resilience of communities, households and individuals to economic and

climate related shocks.4. Develop partnerships with local authorities, NGOs, the private sector, and Donor

Development Assistance programs to leverage investments in natural resources management, build community resilience and facilitate the coordination of development and humanitarian efforts in the BBL area.

5. Incorporate gender and cultural sensitivity into activity programming and reporting.

The following table summarizes the environmental determinations applicable to the specific projects/activities:

Activities Categorical Exclusion

Negative Determination

Positive Determination

Deferral1

Technical assistance and capacity building to improve natural resource management and resiliency to climate shocks, and help mitigate land tenure conflicts.

X X (with conditions)

Improve biodiversity conservation and wildlife management – and reduce poaching - in national parks and protected areas and other biologically significant areas (e.g., Boma-Bandingilo Landscape).

X X (with conditions)

Promote sustainable livelihood development in park, protected area, or other Boma-Bandingilo

X X (with conditions)

1 Deferrals must be cleared through an Amendment to this IEE prior to implementation of any deferred activities. USAID/IPs may utilize the Environmental Screening Tool to assess impacts of deferred activities.

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Activities Categorical Exclusion

Negative Determination

Positive Determination

Deferral

areas.Develop partnerships with local authorities, NGOs, the private sector, and Donor Development Assistance programs to leverage investments in natural resources management, build community resilience and facilitate the coordination of development and humanitarian efforts in the Boma-Bandingilo Landscape area.

X

Incorporate gender and cultural sensitivity into activity programming and reporting.

X

CLIMATE RISK MANAGEMENT

See Climate Risk Management summary in Section 2.

Note well: This South Sudan CRM Matrix still has several gaps, including minimal discussion of climate risks (including water) and no screening narrative. Africa Regional CIL recommends that the IP do the screening before implementation, since the biodiversity interventions laid out are vulnerable to climate risks. 

IMPLEMENTATION

In accordance with 22CFR216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in this IEE and any BEO Specified Conditions of Approval.

DISTRIBUTION:

USAID/South Sudan ABEO/ENRMO/WASH Teams A/CORs and Activity ManagersUSAID/South Sudan Contracts OfficeUSAID/South Sudan Program Development and Analysis Office

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USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATIONPROJECT/ACTIVITY NAME: Conservation of Boma – Bandingilo Landscape

Bureau Tracking ID: South Sudan Conservation Boma-Bandigilo Landscape IEE_882018

Approval: /cleared/ 08/02/18Elise Jensen, Acting Mission Director, USAID S. Sudan Date

Clearance: /cleared/ 7/19/18Jeffery Hill, Director Office of Economic Growth, USAID S. Sudan Date

Clearance: /cleared/ 7/19/18Emmanuel Dijango, Mission Environmental Officer, USAID S. Sudan

Date

Clearance: /cleared/ 7/26/18David Kinyua, Regional Environmental Advisor, E. Africa Region Date

Clearance: /cleared by email/ 7/26/18Muriel Korol, Regional Legal Officer Date

Clearance: /cleared/ 8/03/18Alan Graceau, Acting Deputy Mission Director, USAID S. Sudan Date

Concurrence: /cleared/ 8/8/2018Brian Hirsch, USAID/AFR/SD/EGEA Bureau Environmental Officer, Africa Bureau

/cleared/

Date

8/7/2018Concurrence: Walter Knausenberger, USAID AFR Deputy BEO and Sr. Env.

Policy Advisor Date

Information: /cleared by email/ 8/01/18Emily Rupp, Supervisory Program Officer, USAID S. Sudan Date

Clearance: /cleared/ in AFR EC Tracker / See signing statement*

Roopa Karia, AFR/Bureau Climate Integration Lead Date

* Signing statement: Implementer needs to conduct a thorough post-award screening prior to implementation

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1.0 PROJECT/ACTIVITY DESCRIPTION

1.1 PURPOSE AND SCOPE OF IEE

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22CFR216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID intervention described herein and recommend determinations and, as appropriate, conditions, for these activities. Upon approval, these determinations become affirmed, per 22CFR216 and specified conditions become mandatory obligations of implementation. This IEE also documents the results of the project/activity level Climate Risk Management process in accordance with USAID policy (specifically, ADS 201mal).

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

1.2 PROJECT/ACTIVITY OVERVIEW

In a biologically diverse yet vulnerable area, the Boma-Bandingilo Landscape Activity seeks to build resilient communities and secure wildlife and biodiversity resources for the future. The Boma-Bandingilo landscape is home to a diverse and rich set of natural resources and wildlife and approximately 200,000 people, whose pastoral and agrarian livelihoods remain predominantly dependent on the landscape.

These communities are highly vulnerable to conflict, economic and climate related shocks. Conflict and poverty are key drivers of the poor management of wildlife and depletion of natural resources in the Boma-Bandingilo landscape. Left unprotected and unsustainably managed, the natural resources and biodiversity of the area will continue to be depleted, leading to the further deterioration of the coping capacity of the people, households and communities.

USAID South Sudan’s goal to “Build a foundation for a more stable and socially cohesive South Sudan” is supported by the USAID South Sudan Operational Framework that has two Transitional Objectives (TOs). The Boma-Bandingilo Landscape Activity will be a component of and contribute to the Integrated Essential Services Project (IESP), the primary vehicle for implementing the USAID TO1. The Activity’s community-focused interventions will contribute to TO1 sub objective (SO) 1 - to facilitate community-led responses. The resource management and livelihood diversification interventions will contribute to TO1:SO3 - to strengthen livelihoods and resilience to shocks.

The Activity will be implemented in the Boma-Bandingilo landscape with a focus on Boma National Park, Bandingilo National Park and the wildlife migratory route connecting them. The Boma National Park is comprised of four counties and includes four different pastoral or agro-pastoral ethnic groups/communities: Murle, Anuak, Kachipo, and Jie. The Bandingilo National Park falls within five counties, home to four different, predominantly agro-pastoralist, communities: Mundari, Bari, Pari and a small section of Dinka tribe from Jonglei. The Boma- Bandingilo corridor borders Central Equatoria State to the South West, Jonglei State to the

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West, and Boma State to the East and North East, near the Ethiopia border. The population of Boma state is estimated to be 272,792 people and this project is anticipated to benefit directly between 150,000 – 200,000 people living within and around the Parks.

The Boma-Bandingilo Landscape Activity includes four components that may utilize mutually reinforcing approaches to enhance natural resource and wildlife management and build community and livelihood resilience. Each component is tied to one of the four expected outcomes discussed below. Gender and inclusive engagement across social and ethnic groups will be mainstreamed in all components and activities as appropriate.

Component I: Capacity building for land and natural resource management and

conflict mitigation at the landscape and community levels Component II: Conservation of wildlife at the landscape and community levels Component III: Community level actions to build resilience to economic and

climate related shocks Component IV: Building community and landscape level partnerships for natural

resource management and community resilience.

Protected Areas of South Sudan

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The purpose of this Activity is to build resilient communities and livelihoods and secure wildlife and biodiversity resources in the Boma-Bandingilo Landscape. This Activity directly contributes to the USAID South Sudan Integrated Essential Services Project whose purpose is to increase the resilience of individuals, households, and communities to absorb, adapt to, and recover from shocks.

The key outcomes sought through this Activity are resilient communities and livelihoods as well as secure wildlife and biodiversity habitats. Activity actions and investments will be expected to result in:

1. Increased capacity, plans and systems in place to sustainably manage land and natural resources and mitigate conflict in the Boma and Bandingilo parks and communities in the wildlife migratory corridor.

2. Secure wildlife and biodiversity within the Boma-Bandingilo Landscape.3. Increased resilience of communities, households and individuals to economic and

climate related shocks.4. Develop partnerships with local authorities, NGOs, the private sector, and Donor

Development Assistance programs to leverage investments in natural resources management, build community resilience and facilitate the coordination of development and humanitarian efforts in the BBL area.

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5. Incorporate gender and cultural sensitivity into activity programming and reporting.

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2.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK AND ENVIRONMENTAL DETERMINATIONSThis section summarizes potential adverse environmental and social impacts of Boma_Bandingilo project activities. The information supports analysis sufficient to identify the appropriate mitigation measures and monitoring indicators necessary to avoid or sufficiently reduce impacts of the project activities

Intervention Category 1: Technical assistance and capacity building to improve natural resource management and land use management, and help mitigate land tenure conflicts.

Entailed activities:

Increased capacity, plans and systems in place to sustainably manage land and natural resources and mitigate conflict in the Boma and Bandingilo parks and communities in the wildlife migratory corridor.

Capacity Needs Assessment (CNA) of Boma and Bandingilo park staff. Training park managers and rangers in priority capacity needs. Facilitating conflict resolution involving park managers, rangers and communities; and Developing guidelines and tools/manuals for natural resources-based conflict

management. Map community institutions and capacity needs for land use and natural resource

management. Develop guidelines for community-based land use planning and natural resources

management. Train County(s), Community and village councils in land and natural resources use

planning. Develop community-based land use and natural resources management plans. Promote implementation of sustainable land and natural resources use practices. Survey and case studies on the dynamics between natural resources and livelihoods. Develop guidelines for conflict management for counties and other lower authorities and

community. Establish learning opportunities for counties and other lower authorities on conflict

management. Build local capacity development (e.g., NGOs, CSOs, cooperatives) in biodiversity

conservation.

The Boma_Bandingilo project entails policy, capacity building and land-use initiatives that are specifically designed to impact NRM and/or environmental decision making in South Sudan. And although any adverse impacts would be indirect in nature, the relative influence of these types of policies on environmental outcomes warrants the establishment of conditions. Other activities proposed under this activity are primarily facilitation and training; these activities generally have little or no impact on the environment, and therefore are categorically excluded from further analysis.

The following table summarizes the recommended determinations based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22CFR216. Specified conditions become mandatory obligations of implementation, per ADS 204.

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TABLE 2.1 INTERVENTION CATEGORY 1

Illustrative Activity Recommended Determination

Capacity Needs Assessment (CNA) of Boma and Bandingilo park staff.

Training park managers and rangers in priority capacity needs.

Map community institutions and capacity needs for land use and natural resource management.

Categorical Exclusion, per §216.2(c)2(i) Education, technical assistance, or training programs; (iii) Analyses, studies, academic or research workshops and meetings; and(v) Document and information transfers.

(xiv) Studies, projects, or programs intended to develop the capability of recipient countries to engage in development planning.

Facilitating conflict resolution involving park managers, rangers and communities.

Developing guidelines and tools/manuals for natural resources-based conflict management.

Negative Determination, subject to the following conditions:

1. Technical assistance and training will include environmental awareness and sensitivity components, including exposure to the principles and procedures of Environmental Impact Assessment (EIA).

2. Content review for promotion of specific NRM practices. Prior to any training activities or other promotion of specific NRM practices, an expert review of the specific practices must be completed, drawing on IP, USAID, or 3rd-party consultant expertise, as appropriate. This review must assess the potential for adverse environmental impacts stemming from implementation of target NRM practices/objectives under participatory governance structures, including the possibility of selective or incomplete adoption of best management practices. (For example, clearance of natural forest for tree lots, non-sustainable harvesting levels of non-timber forest products, poorly controlled use of pesticides, fertilizers or other inputs, clearing of new or protected land for cultivation, etc.).

Develop guidelines for community-based land use planning and natural resources management.

Train County(s), Community and village councils in land and natural resources use planning.

Develop community-based land

Negative Determination, subject to the following conditions:

1. Hold mediated processes, run by an independent third party, whereby all stakeholders – from extraction companies to local residents to environmental organizations to investors – are invited to participate in the planning process and be

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Illustrative Activity Recommended Determination

use and natural resources management plans.

Promote implementation of sustainable land and natural resources use practices.

heard. This approach should lead to outcomes consistent with principles of biodiversity conservation in protected areas.

2. Unless the conditions of Section 118 of the Foreign Assistance Act of 1961, as amended, are followed, no assistance will be provided for the following activities:

- Conversion of forest lands to the rearing of livestock

- Construction, upgrading, or maintenance roads which pass through relatively undegraded forest lands

- Colonization of forest lands- Construction of dams or other water control

structures that flood relatively undegraded forest lands

3. All community-based land use and natural resources management plans must substantially conform to good practices as set out in the CBNRM chapter of USAID's Sector Environmental Guidelines (http://www.usaidgems.org/Sectors/cbnrm.htm ).

4. Land use planning must integrate or otherwise reflect current data and analysis on environmental trends, including principles of sustainable NRM and GCC adaptation strategies. Data and analysis may be drawn from USAID, other bilateral donor agencies, International Financial Institutions, Multilateral Development Banks, or other internationally recognized research or development entities.

5. USAID technical assistance to community conservancies on forest management and land use plans that include measures to: Prevent introduction of exotic plant species not

already cultivated in the area, where there is any reasonable chance that this may facilitate their introduction or spread within a protected area. The training/extension review must specifically consider this issue and the soundness of species choices generally.

Prevent or mitigate adverse economic consequences on local communities, including from loss of usual and customary use of resources

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Illustrative Activity Recommended Determination

Otherwise assure that policy is fully consistent with accepted principles of natural resource management. See http://www.usaidgems.org/Sectors/forestry.htm

Build local capacity development (e.g., NGOs, CSOs, cooperatives) in biodiversity conservation.

Negative Determination, subject to the following conditions:

1) Policy development must integrate or otherwise reflect current data and analysis on regional environmental trends, including principles of biodiversity conservation and sustainable NRM adaptation strategies. Data and analysis may be drawn from USAID, other bilateral donor agencies, International Financial Institutions, Multilateral Development Banks, or other internationally recognized research or development entities.

Intervention Category 2: Improve wildlife and biodiversity management within the Boma-Bandingilo Landscape.

Illustrative Activities: i) Work with and provide support to park authorities for Boma and Bandingilo parks to

enable them to conduct anti-poaching and reduce illegal trafficking of wildlife; implement park management plans; and work with community-based conservation groups to monitor wildlife assets; conduct wildlife surveys in Boma-Bandingilo Landscape and updating wildlife information databases.

ii) Strengthen linkages of Boma and Bandingilo park authorities with the USAID funded East African region programs for monitoring and managing wildlife crime and trafficking activities.

iii) Work with local authorities to identify some communities to pilot the establishment of Community Conservation Committees or other conservation groups to monitor wildlife and promote wildlife conservation.

iv) Develop and implement innovative approaches and tools to make multi-stakeholder mutual accountability systems work for wildlife conservation.

v) Design and support implementation of an action plan for anti-poaching and other wildlife protection activities.

vi) Design and support a system for monitoring trafficking of wildlife products in the field, at airports and major trade routes.

vii) Facilitate the establishment of trans-boundary collaboration with East Africa countries; Facilitate engagement in international wildlife conservation agenda and processes.

The activities in this intervention category aim to improve wildlife and biodiversity management in the Boma-Bandingilo areas. However, some of the management activities have the potential

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to directly and adversely impact natural resources and the environment. For instance, preventing human-wildlife conflict (e.g., situations where animals attack people or their farmland) and strengthening of patrolling could result in injured or killed animals in an effort to resolve potential conflicts with communities or poachers.

While the facilitation of working groups to develop park management approaches will not have direct negative impacts on the environment, the objective of these efforts is to change management and use of the natural environment in and near protected areas. Thus, though the change sought is environmentally beneficial (i.e., strengthened biodiversity conservation and NRM), possible “failure modes” exist that could result in adverse environmental impacts. For example, stakeholders could formulate management approaches that are unrealistic or counterproductive, with potential impacts on the environment (e.g., endangering a species in the park).

TABLE 2.2. INTERVENTION CATEGORY 2

Illustrative Activity Recommended Determination

Conduct wildlife surveys in Boma-Bandingilo Landscape and update wildlife information databases.

Strengthen linkages of Boma and Bandingilo park authorities with the USAID funded East African region programs for monitoring and managing wildlife crime and trafficking activities.

Work with community-based conservation groups to monitor wildlife assets.

Categorical Exclusion, per §216.2(c)2(iii) Analyses, studies, academic or research workshops and meetings; and(v) Document and information transfers.

Provide support to park authorities for Boma and Bandingilo parks to enable them to conduct anti-poaching and reduce illegal trafficking of wildlife.

Strengthen patrolling of the national park by rangers deployed to intercept poachers or other people engaged in illegal environmental activities.

Design and support implementation of an action plan

Negative Determination, subject to the following conditions:

1. TA and training in anti-poaching techniques, in conjunction with anti-poaching organizations, to park rangers and community groups.

2. Where necessary, park rangers should be responsible for dispatching injured animals to assure it is done humanely, that the species is not of special concern, and make a determination on whether poaching occurred.

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Illustrative Activity Recommended Determination

for anti-poaching and other wildlife protection activities.

Prevent human-wildlife conflict by, e.g., removing injured and dangerous animals.

Negative Determination, subject to the following conditions:

1. Training communities in methods to protect their crops from elephants or other animals, and training communities in keeping bees to ward off elephants. Conduct community sensitization to reduce the use of snares, which injure the animals.

2. Where necessary, park rangers should be responsible for dispatching injured animals to assure it is done humanely, that the species is not of special concern, and make a determination on whether poaching occurred. 

Intervention Category 3: Promote sustainable livelihood development in park, protected area, or other Boma-Bandingilo areas.

i) Assist in ensuring the availability of and access to techniques and technologies for nurturing of viable livelihoods.

ii) Identify and promote more efficient techniques to reduce waste and increase profitability of charcoal making.

iii) Tapping, harvesting and handling Gum Arabic, and other commercially viable non-timber forest products.

iv) Explore innovative ways to enable local communities to support tree planting by the community members or in common areas to supply the need for fuel and offset the unsustainable harvesting of wood in protected areas.

v) Assessment and promotion of value chains for Gum Arabic, Shea Butter and fisheries resources or other viable value chains.

vi) Setting up producer group to support marketing and market access.vii) Training farmers/communities on options to add value to local products.

a. Training village/community extension agents on climate\vulnerability and climate adaptation technologies (including Climate Smart Agriculture).

b. Support to Climate Smart Agriculture practices that increase incomes and facilitate and adaptation to climate change.

Sustainable livelihood initiatives are intended to facilitate and promote adoption of more environmentally benign economic activities than logging, hunting, or land clearance for agriculture, and thus to conserve biodiversity and strengthen NRM in sensitive, at-risk environments. However, market development can trigger non-sustainable as well as sustainable harvesting levels, with attendant land clearing, pesticide use, etc. In this case, their biodiversity impacts can become negative rather than beneficial, and other adverse impacts (e.g., related to inappropriate pesticide use) are possible. The over-exploitation of natural resources may also have adverse impacts on biodiversity and forest ecosystems and the long-term viability of

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sustainable livelihoods. As such, effective strategies will balance the ecological and economic dimensions of natural resource management.

Any reforestation efforts risk the introduction of non-native species into protected areas; safeguards must be put in place to avoid inappropriate choices of species and techniques, including water and soil management and conservation techniques. Section 119 of the Foreign Assistance Act of 1961, as amended, (FAA) provides that no “direct or indirect assistance . . . for actions which significantly degrade national parks or similar protected areas or introduce exotic plants or animals in such areas.” Moreover, unless the conditions of Section 118 of FAA are followed, no assistance will be provided for the following activities: conversion of forest lands to the rearing of livestock; construction, upgrading, or maintenance roads which pass through relatively undegraded forest lands; colonization of forest lands; and construction of dams or other water control structures that flood relatively undegraded forest lands.

The potential adverse impacts stemming from sustainable livelihood initiatives are heightened by proximity to protected areas and habitats otherwise rich in biodiversity and other resources. The level of environmental risk in these scenarios is relatively higher than in other contexts—the existence of a protected area already denotes an environment of certain importance. The key challenge is empowering rural populations in and around protected areas with economic opportunity and livelihood options that align with conservation objectives.

The primary concern that a recommended determination must address is that of assuring that adequate consideration has been given and measures taken to limit the possibility of non-sustainable harvesters/production techniques benefiting from the activity.

TABLE 2.3 . INTERVENTION CATEGORY 3

Illustrative Activity Recommended Determination

Build capacity in small-scale sustainable natural resource management livelihoods such as production of Gum Arabic, Shea Butter, fisheries resources, and other goods.

Negative Determination, subject to the following conditions:

1. Prior to commencement of specific NRM livelihoods, the Implementing Partner must submit a memorandum to the A/COR and MEO specifically addressing how the risks of benefits accruing to non-sustainable harvesters/production techniques will be controlled and limited.

2. The measures specified in the memorandum must be implemented, and the memorandum will include reporting/verification measures regarding implementation of these risk control measures.

3. The memorandum must be cleared by the A/COR and MEO prior to implementation of the activity.

4. The IP must incorporate the following best practices: Fisheries management to increase natural productivity

and fish populations for human consumption should occur by conserving habitat and breeding grounds and eliminating destructive fishing gear. o Activities must incorporate and promote good

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Illustrative Activity Recommended Determination

practice as set out in the Wildcaught Fisheries and Aquaculture chapter of USAID’s Sector Environmental Guidelines (http://www.usaidgems.org/Sectors/aquafish.htm ).

Maintain areas of native habitat within the agricultural landscape, giving priority to intact and ecologically important areas, to support important ecological processes such as pollination and seed dispersal that are critical for many agricultural crops and for forest regeneration.o Activities must incorporate and promote good

practice as set out in the Agriculture chapter of USAID’s Sector Environmental Guidelines (http://www.usaidgems.org/Sectors/agriculture.htm ).

Integrate a watershed and agro-ecological approach to food security within agriculture sector activities to enhance sustainability and resilience and reduce threats to biodiversity.

Promotion of commercial, market or value chain linkages (e.g., for Gum Arabic, Shea Butter, fisheries resources.)

Negative Determination, subject to the following conditions:

The integrity of environmental and social considerations and safeguard processes will be reviewed as commercial, market or value chain linkages are promoted. USAID will be notified when issues or concerns are identified, and these will be integrated as part of regular project reporting. USAID will assess reported issues and determine appropriate follow-up actions, which may include actions ranging from providing additional technical assistance and/or capacity building to activity redesign or cessation.

The IP must incorporate the following best practices: Include marine fisheries as a value chain to improve

management and governance of coastal zones.o Activities must incorporate and promote good

practice as set out in the Wildcaught Fisheries and Aquaculture chapter of USAID’s Sector Environmental Guidelines (http://www.usaidgems.org/Sectors/aquafish.htm ).

Fisheries management to increase natural productivity and fish populations for human consumption should occur by conserving habitat and breeding grounds and

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Illustrative Activity Recommended Determination

eliminating destructive fishing gear. Maintain areas of native habitat within the agricultural

landscape, giving priority to intact and ecologically important areas, to support important ecological processes such as pollination and seed dispersal that are critical for many agricultural crops and for forest regeneration.o Activities must incorporate and promote good

practice as set out in the Agriculture chapter of USAID’s Sector Environmental Guidelines (http://www.usaidgems.org/Sectors/agriculture.htm ).

Integrate a watershed and agro-ecological approach to food security within agriculture sector activities to enhance sustainability and resilience and reduce threats to biodiversity.

Training village/community extension agents on climate\vulnerability and climate adaptation technologies (including, Climate Smart Agriculture).

Support to Climate Smart Agriculture practices that increase incomes and facilitate and adaptation to climate change.

Negative Determination, subject to the following conditions:

Policy development must integrate or otherwise reflect current data and analysis on regional environmental trends, including principles of sustainable NRM and GCC adaptation strategies. Data and analysis may be drawn from USAID, other bilateral donor agencies, International Financial Institutions, Multilateral Development Banks, or other internationally recognized research or development entities.

Intervention Category 4: Develop partnerships with local authorities, NGOs, the private sector, and Donor Development Assistance programs to leverage investments in natural resources management, build community resilience and facilitate the coordination of development and humanitarian efforts in the BBL area.

i) Mapping stakeholders and designing stakeholder Partnership Strategy at landscape level.

ii) Conduct an assessment of opportunities for co-location and collaboration as well as synergies with activities supported by USAID and other Stakeholders within the landscape.

iii) Assistance establishing PPPs (e.g., engaging counterparts and private-sector entities to identify, discuss, negotiate, and agree on partnerships).

i) Participate in regular coordination meetings with other USAID implementing partners in South Sudan and the BBL area.

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The majority of activities proposed under this activity are primarily partnership facilitation and strengthening, training of analysts and economists, promotion of civil society, policy and law reform, education on business skills, financial capacity building, and extension of credit. These activities generally have little or no impact on the environment, and therefore are categorically excluded from further analysis. However, PPPs established with USAID support will incorporate as a core value the fostering of an environmentally sound/sustainable approach, and this value will be fully mainstreamed and integrated in their programming and activities.

TABLE 2.4. INTERVENTION CATEGORY 4

Illustrative Activity Recommended DeterminationAssistance establishing PPPs (e.g., engaging counterparts and private-sector entities to identify, discuss, negotiate, and agree on partnerships)

Mapping stakeholders and designing stakeholder Partnership Strategy at landscape level.

Conduct an assessment of opportunities for collocation and collaboration as well as synergies with activities supported by USAID and other Stakeholders within the landscape.

Categorical Exclusion, per §216.2(c)2

(i) education, technical assistance or training programs; (iii) analyses, studies, academic or research workshops and meetings; (xiv) studies, projects or programs intended to develop capability of recipient countries to engage in development planning.

Intervention Category 5: Incorporate gender and cultural sensitivity into activity programming and reporting.Illustrative activities

i) Gender and inclusive engagement across social and ethnic groups will be mainstreamed in all components and activities as appropriate.

ii) Conduct an assessment of different impacts of land use and natural resources use conflicts on men and women;

iii) Develop and implement a gender and inclusiveness strategy for the project. iv) Incorporate gender and cultural sensitivity into activity programming and reporting.

These activities generally have little or no adverse impact on the environment, and therefore are categorically excluded from further analysis.

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TABLE 2.5. INTERVENTION CATEGORY 5

Activity Recommended Determination

Gender and inclusive engagement across social and ethnic groups will be mainstreamed in all components and activities as appropriate.

Conduct an assessment of different impacts of land use and natural resources use conflicts on men and women.

Develop and implement a gender and inclusiveness strategy for the project.

Incorporate gender and cultural sensitivity into activity programming and reporting.

Categorical Exclusion per §216.2(c)2(i): education, technical assistance or training programs except to the extent such programs include activities directly affecting the environment

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TABLE 2.6. CLIMATE RISK MANAGEMENT*

1.1: Defined or Anticipated Tasks or Intervention

1.2: Time-frame

1.3: Geo-graphy

2: Climate Risks*

3: Adaptive Capacity

4: Climate Risk Rating*

5: Opportunities* 6.1: Climate Risk Management Options

6.2: How Climate Risks are Addressed in the Activity*

7: Next Steps for Activity Implementation

8: Accepted Climate Risks*

Support

improved

management

of natural

resources,

including

wildlife

0-20

years

Boma-

Bandingilo

Extreme

weather events

(e.g., drought,

flooding, etc.)

are cyclic in the

country,

impacting

habitats,

landscapes and

natural

resources with

limited time for

response and

recovery

Current

climate

change

information

and

institutional

capacity is

weak.

Medium Existing climate data

tools and spatial

mapping can assist

with decision making.

SERVIR (A joint development initiative of NASA and USAID, SERVIR works in partnership with leading regional organizations world-wide to help developing countries use information provided by Earth-observing satellites and geospatial technologies to manage climate risks and land

use).  IUCN platform working

with civil society to improve natural resource management.

Activity will encourage

utilization of information

systems for climate

change; build relevant

institutional capacity on

climate change decision

making, planning and

enforcement; support

improved land use

planning.

Foster increased dialogue on integrated planning and policies; increase availability and accessibility of climate change data for decision making

The project

implementation

stage will

incorporate

adaptive

measures in the

program

description and

SOW for

implementation

None

* Note well: This South Sudan CRM Matrix still has several gaps, including minimal discussion of climate risks (including water) and no screening narrative. Africa Regional CIL recommends that the IP do the screening before implementation, since the biodiversity interventions laid out are vulnerable to climate risks. 

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3.0 CONDITIONS AND MITIGATION MEASURES

3.1 CONDITIONS

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

3.1.1 During Pre-Award:

3.1.1.1 Awards: The A/COR, in coordination with the A/CO, will ensure all awards and sub-awards, include environmental compliance requirements.

3.1.2 During Post-Award:

3.1.2.1 Post-Award Briefings: The A/COR and/or the cognizant environmental officer(s) (e.g., MEO, REA, BEO) will provide post-award briefings for the IP on environmental compliance responsibilities.

3.1.2.3 Workplans and Budgeting: The A/COR will ensure the IP integrates environmental compliance requirements in work plans and budgets to comply with requirements, including EMMP implementation and monitoring.

3.1.2.4 Staffing: The A/COR, in coordination with the IP, will ensure all awards have staffing capacity to implement environmental compliance requirements.

3.1.2.5 Records Management: The A/COR will maintain environmental compliance documents in the official project/activity file and upload records to the designated USAID environmental compliance database system.

3.1.2.6 Host Country Environmental Compliance: The A/COR will assist the IP to comply with applicable and appropriate host country environmental requirements unless otherwise directed in writing by USAID. However, in the case of a conflict between the host country and USAID requirements, the more stringent shall govern.

3.1.2.7 Work Plan Review: The A/COR will ensure the IP verifies, at least annually or when activities are added or modified, that activities remain with the scope of the IEE. Activities outside of the scope of the IEE cannot be implemented until the IEE is amended.

3.1.2.8 IEE Amendment: If new activities are introduced or other changes to the scope of this IEE occur, an IEE Amendment will be required.

3.1.2.14 USAID Monitoring Oversight: The A/COR or designee, with the support of the cognizant environmental officer(s) (e.g., MEO, REA, BEO), will ensure monitoring

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of compliance with established requirements (e.g., by desktop reviews, site visits, etc.).

3.1.2.16 Environmental Compliance Mitigation and Monitoring Plan: The A/COR will ensure the IP develops, obtains approval for, and implements Environmental Mitigation and Monitoring Plans (EMMPs) that are responsive to the stipulated environmental compliance requirements.

3.1.2.17 Environmental Compliance Reporting: The A/COR will ensure the IP includes environmental compliance in regular project/activity reports, using indicators as appropriate; develops and submits the Environmental Mitigation and Monitoring Reports (EMMRs); and completes and submits a Record of Compliance (RoC) describing their implementation of EMMP requirements in conjunction with the final EMMR or at the close of sub activities (as applicable). And where required by Bureaus or Missions, ensure the IP prepares a closeout plan consistent with contract documentation for A/COR review and approval that outlines responsibilities for end-of-project operation, the transition of other operational responsibilities, and final EMMR with lessons learned.

3.1.2.18 Corrective Action: When noncompliance or unforeseen impacts are identified, IPs notify the A/COR, place a hold on activities, take corrective action, and report on the effectiveness of corrective actions. The A/COR initiates the corrective action process and ensures the IP completes and documents their activities. Where required by Bureaus or Missions, ensure Record of Compliance is completed.

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4.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION The determinations recommended in this document apply only to projects/activities and sub-activities described herein. Other projects/activities that may arise must be documented in either a separate IEE, an IEE amendment if the activities are within the same project/activity, or other type of environmental compliance document and shall be subject to an environmental analysis within the appropriate documents listed above.

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

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

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

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

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

Promote timber harvesting per FAA 117 and 118;

Lead to new construction, reconstruction, rehabilitation, or renovation work per §216.2(b)(1);

Support agro-processing or industrial enterprises per §216.1(b)(4);

Provide support for regulatory permitting per §216.1(b)(2);

Lead to privatization of industrial facilities or infrastructure with heavily polluted property per §216.1(b)(4);

Procure or use genetically engineered organisms per §216.1(b)(1); and/or

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

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5.0 REVISIONSPer 22CFR216.3(a)(9), when ongoing programs are revised to incorporate a change in scope or nature, a determination will be made as to whether such change may have an environmental impact not previously assessed. If so, this IEE will be amended to cover the changes. Per ADS 204, it is the responsibility of the USAID A/COR to keep the MEO/REA and BEO informed of any new information or changes in the activity that might require revision of this environmental analysis and environmental determination.

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