usaid environmental guidelines purpose and overview ymep environmental training overview
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USAID Environmental GuidelinesPurpose and Overview
YMEP Environmental Training Overview
Fate and Transport of Pollution in the Environment
Sources
Pathway
Target
Exposure Scenario
Protecting Against Environmental Risk
Risk = Hazard x Exposure
hazard: A circumstance/event with potential to cause harm. A hazard itself presents no risk until something is exposed to it.
exposure: A particular amount of time something comes in contact with a hazard or the number of times something comes in contact with a hazard.
Hazard x Exposure = No Risk Hazard x Exposure = No Risk
There really is no such thing as zero risk
22 CFR 216 Regulations
22 CFR 216 codifies USAID’s procedures for assessing assessment of our programsApplies to every program, project, activity, and amendment supported with USAID funds
– Every USAID Officer Who Has a Role in USAID Funded Projects
– Every Partner Who Seeks USAID FundsCompliance with the procedures is mandatory
ADS Chapter 204 Environmental Procedures
This chapter provides policy directives and required procedures on how to apply Title 22 of the Code of Federal Regulations,
Reg 216: The big picture
system, Reg. 216 features a tiered review system to focus review effort where it is needed.
Increasing risk/impact
Most activities are cleared with:
Categorical Exclusion
Initial environmental examination
Activities specified by the regulation as having minimal environmental impact
A much shorter, simpler version of a full EIA study
Full EIA Requires a professional team, 2+ person months
Reg 216 specifies that an IEE must reach 1 of 2 decisions:
Positive determination, (significant impacts likely, do full EIA)
Negative determination, (no significant impacts, proceed with activity)
“Exempt” activities often have significant adverse impacts.
Good practice requires mitigating these impacts, where possible.
1.International disaster assistance2.Other emergency situations 3.Circumstances with “exceptional
foreign policy sensitivities”
Under Reg 216, EXEMPTIONS are ONLY. . .
Exemptions require a formal determination by the Administrator or Assistant Administrator that includes consultation with CEQ regarding the environmental consequences of the proposed program, project or activity.
Exemptions from 216 Requirements
USAID Screening Categories:Categorical Exclusions
1. Education, tech. assistance, training2. Documents or information transfers3. Analyses, studies, academic or research
workshops and meetings 4. Support to intermediate credit
institutions where USAID does not review loans
5. Nutrition, health, family planning activities except where infectious medical waste is generated
A specific set of activities believed to have minimal environmental impacts have been identified for possible exclusion from the 216 Illustrative examples include:
No categorical exclusions are
possible when an activity involves
pesticides
And certain other situations where USAID does not have direct knowledge or control
Categorical exclusions exist AT THE DISCRETION of
the BEO
New Environmental Executive guidelines
on Categorical Standards emphasize need for case by case
review of CATEX applicabiility
New Guidance Requires Affirmative Evaluation of CATEX Applicability
Institutional Capacity Building Case Study
Project Includes:• Senior LT Advisor to Ministry of Mining on Best Practices• Assist in c concession negotiations• Supervise cadastre and legal reform work• STTA on concessions and legal reform• Training Ministry Staff
Basic Reg. 216 compliance documents
Initial Environmental Examination
1. Goals and purpose of project; list of activities
2. Baseline information3. Evaluation of potential
environmental impacts4. Recommended findings,
mitigation & monitoring
Request for Categorical Exclusion
1.Goals and purpose of project: list activities
2.Justification for a Categorical Exclusion (must cite the appropriate section of Reg. 216.)
The IEE is USAID’s “preliminary assessment”
The RCE is a simple
document used when ALL
activities are “low risk”
A “facesheet” accompanies both the IEE & the CatEx
Request
1 2
3
No activities may be
implemented without
APPROVED Reg. 216
environmental documentation
Environmental Screening
YMEP Environmental Training Overview
Recommendation Reg. 216 terminology
Implications(if IEE is approved)
No significant adverse environmental impacts
NEGATIVEDETERMINATION
Activity passes environmental review
With specified mitigation and monitoring, no significant environmental impacts
NEGATIVEDETERMINATIONWITH CONDITIONS
The activity passes environmental review on the condition that the specified mitigation and monitoring is implemented
Significant adverse environmental impacts are possible
POSITIVEDETERMINATION
Do full EAor redesign activity
Not enough information to evaluate impacts DEFERRAL
You cannot implement the activity until the IEE is finalized
• For each activity addressed, the IEE makes one of 4 recommendations regarding its possible impacts:
Recommended Determinations in the IEE
Umbrella IEEs for “Umbrella” Projects
G.1 Umbrella projects and USAID’s Environmental Procedures
The basic procedures described in Chapters 1–4 of this manual assume that proposed activities are sufficiently well-defined that the screening process can be undertaken and, if necessary, an IEE can be prepared.
However, proposals often include activities that are not fully defined at the time the proposal is submitted. “Umbrella projects” are a common example of this situation. In an umbrella project, a number of small-scale activities are funded through subgrants under a larger project.
Umbrella projects are commonly used to implement community-driven development schemes. They provide a mechanism to fund community proposals for small-scale activities. They may also be used to fund micro and small enterprise subprojects.Typically, a USAID partner organization receives overall funding for the umbrella project. The partner then functions as a subsidiary grantmaker, using a portion of the overall funding to award small-scale grants.
Under certain circumstances, however, USAID itself assumes the role of managing the subproject proposal and grant-making process.
CLP Program is an Example of an Umbrella IEE
Environmental Assessments/ Environmental Impact Statements
PERSUAPS
Programmatic Environmental Assessments
Beyond the IEE
YMEP Environmental Training Overview
EA Requirements
The full EA study includes:
A formal scoping process precedes the study to ID issues to be addressed
Analysis of environmental impacts is much more detailed
Alternatives* must be formally defined. The impacts of each alternative must be identified & evaluated, and the results compared.
Public participation is usually required.
A professional EIA team is usually required.
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2
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*includes the project as proposed, the no-action alternative at least one other real alternative
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5
Programmatic Approaches
An Office of USAID may undertake an environmental assessment within a sector (agriculture, road construction, etc.) or a larger program to help define and mitigate potential environmental concerns in the design of a program or strategy. Such an overall assessment is known as a Programmatic Environmental Assessment (PEA) and can serve as a general assessment of a sector or provide the basis for future environmental reviews, at either project or sub-project level.
Section 216.6(d) of Reg. 216:(d) PROGRAM ASSESSMENT: Program Assessments may be appropriate in order to:-- assess the environmental effects of a number of individual actions and their cumulative environmental impact in a given country or geographic area, or-- the environmental impacts that are generic or common to a class of agency actions, or-- other activities which are not country-specific.
Programmatic Environmental Assessment
Pesticide Evaluation Report & Safer Use Action Plan (PERSUAP)
• Originated in the Africa Bureau, but increasingly being adopted elsewhere, the PERSUAP constitutes the pesticide analysis of the IEE*, or takes its place.– The PERSUAP can be self-standing, be attached to the
IEE, or submitted later to resolve a pesticide use deferral – PERSUAP has two major parts:
Pesticide Evaluation
Report&1
Safer Use Action Plan
2
Response to thePesticide Procedures requirements
Identifies actions and actors for mitigation & monitoring,
including compliance with host country & private** procedures
Monitoring Environmental Compliance
YMEP Environmental Training Overview
USAID Must Monitor IP Performance with Environmental Requirements
Implementing Partners must provide USAID with verifiable monitoring information about environmental compliance.
Definition: Environmental monitoring is BOTH. . .
1.Systematic measurement of key environmental indicators over time
(is the mitigation measure sufficient, effective?)
2. Systematic verification of mitigation
(are the prescribed measures being implemented?)
Environmental monitoring is a necessary complement to mitigation.
It should be a normal part of monitoring project results.
Environmental Monitoring and Mitigation Plans
Mitigation and monitoring is set out in Environmental Mitigation and Monitoring Plans (EMMPs)