ACTIVITY DATA - ecd.usaid.gov · Web viewLocal farmers in Isiolo use pesticides like Thiodan, Karate, Duduthrin, Bestox, Actellic super, and Sherpa plus to protect their green gram

INITIAL ENVIRONMENTAL EXAMINATIONACTIVITY DATA Activity Name: USAID Food for Peace (FFP) FY 2019 Request for

Applications (RFA) for Development Food Security Activities in Kenya

Amendment (Y/N): N Geographic Location(s) (Country/Region):

Northwest Kenya1

Implementation Start/End: Pre-Award, To be determined upon award(s) Solicitation/Contract/Award Number:

To be determined

Implementing Partner(s): To be determined upon award(s) Link to IEE: DCHA FFP FY19 RFA IEE Link to Other, Related Analyses: ● Kenya 118/ 119

● Climate Risks in FFP Geographies ● Kenya PERSUAPs2 (REGAL-AG, REGAL-IR, KAVES

ORGANIZATIONAL/ADMINISTRATIVE DATA Implementing Operating Unit(s): (e.g. Mission or Bureau or Office)

Office of Food for Peace (FFP), Bureau for Democracy, Conflict and Humanitarian Assistance (DCHA)

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

Same as above

Funding Account(s): Title II, Community Development Funds (CDF) Funding Amount: $186 million Other Affected Unit(s): Africa Bureau, East Africa Regional Mission (Nairobi) Lead BEO Bureau: Democracy, Conflict and Humanitarian Assistance

(DCHA) Prepared by: Environmental Compliance Support (ECOS) contract Date Prepared: March, 2019

ENVIRONMENTAL COMPLIANCE REVIEW DATA Analysis Type: Initial Environmental Examination Environmental Determination(s): Positive Determination, Deferral

IEE Expiration Date: 2023, End of Awards

1 Isiolo, Marsabit, Samburu, and Turkana counties2 These PERSUAPS may be extended as USAID/Kenya is in the process of developing a new Mission-wide Feed the Future PERSUAP.

FY 19 Kenya RFA IEE1

https://www.climatelinks.org/resources/climate-risks-food-peace-geographies-kenya

Additional Analyses/Reporting Required:

Implementing partners to develop Supplemental IEEs

Climate Risk Rating: Low __X___ Moderate __X___ High __X___

THRESHOLD DECISION MEMO AND SUMMARY OF FINDINGSPURPOSE AND SCOPE OF THE INITIAL ENVIRONMENTAL EXAMINATIONThe purpose of this Initial Environmental Examination is to establish environmental compliance procedures and templates3 for future awarded activities under the Food for Peace (FFP) Fiscal Year 2019 Request for Application (RFA) for Kenya Development Food Security Activities.

In line with the phased approach outlined in the RFA (and described further below), the conditions of this IEE require that environmental and climate risk analysis be undertaken first at the research/collaboration level (Phase 1), and again prior to a systems-driven implementation (Phase 2) when Phase 2 activities are well-defined.

ACTIVITY SUMMARYAs specified in the Kenya FY 19 RFA, these activities will contribute to reducing acute malnutrition in Kenya.

ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK MANAGEMENT RATINGSA Positive Determination, is recommended for all commodity fumigation activities, pursuant to 22 CFR 216.3(b)(l)(iii).

A Deferral is recommended for all other interventions, pursuant to 22 CFR 216.3(a)(7)(iv), that are not yet well defined in scope or technical approach.

Low, moderate, and high climate risk ratings were identified for Commodity Fumigation, per ADS201mal

BEO SPECIFIED CONDITIONS OF APPROVALCondition 1: Applicant to submit Environmental Safeguards Plan.

Condition 2 : Awardee to develop Supplemental IEE for Mission and Washington clearance4.

Condition 3: Implement environmental monitoring requirements. This includes development and alignment of Environmental Mitigation and Monitoring Plan (EMMP) with performance M&E systems.

3 Word versions of the required templates can be found at a Google drive here: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS84 The Supplemental IEE can also be referred to as the “activity-level IEE.”


https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8

Condition 4: Report on USAID environmental compliance. All activities are required to submit Environmental Status Reports (ESRs5) annually before the Pipeline Resource Estimate Proposal (PREP). Additional reporting is reflected in the Annual Results Report (ARR).

Condition 5: Develop an Environmental Assessment for any actions with potential for significant impact to ecological habitats, as determined by USAID.

Condition 6: Plan for a Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP), which includes for pesticide procurement and/or use (e.g. agriculture, livestock, public health, construction), and/or commodity fumigation mitigation requirements.

Condition 7: Support the Mission in the development of any Best Practice Review (BPR) for environmental safeguarding.

Condition 8: Ensure compliance with partner country environmental regulations.

IMPLEMENTATIONIn accordance with 22 CFR 216 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 Sections 3, 4, and 5 of the IEE, including any BEO Specified Conditions.

5 The ESR is similar to the Environmental Mitigation and Monitoring Report (EMMR) used elsewhere in USAID. However, the ESR meets both purposes of reporting and budget planning for environmental compliance.


USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

ACTIVITY NAME: USAID Food for Peace (FFP) FY19 Request for Applications Initial Environmental Examination (RFA IEE) for Development Food Security Activities in Kenya

Bureau Tracking ID: DCHA FFP FY19 Kenya RFA IEE

Approval: ___________________________________________Matthew Nims: FFP Deputy Director

____________Date

Clearance: ___________________________________________Michael Keegan, Acting Grants and Contracts Services Team Leader, FFP

____________Date

Clearance: ___________________________________________Kyle Rearick: DCHA Climate Integration Lead

____________Date

Concurrence:

___________________________________________Erika J. Clesceri: DCHA Bureau Environmental Officer

____________Date

DISTRIBUTION:

Washington: Brian Hirsch (Africa BEO), Walter Knausenberger (Senior Advisor, Africa Bureau), Allison Brown (Environmental Advisor, Africa Bureau), Roopa Karia (CIL, Africa Bureau), William Thomas (BFS BEO) and Etienne Yonly (FFP Senior Contracts and Grants Specialist).

Field: David Kinyua (Eastern Africa REA), Wilkister Magangi (Kenya MEO & CIL)


TABLE OF CONTENTS1.0 ACTIVITY DESCRIPTION 7

1.1 PURPOSE AND SCOPE OF IEE 71.2 ACTIVITY OVERVIEW 71.3 ACTIVITY DESCRIPTION 8

2.0 BASELINE ENVIRONMENTAL INFORMATION 102.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL) 102.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS, ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS 14

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL AND CLIMATE RISK 153.1 ENVIRONMENTAL IMPACTS OF COMMODITY FUMIGATION 153.2 CLIMATE RISKS TO COMMODITY FUMIGATION 173.3 OTHER FFP PROGRAM AREAS AND ELEMENTS 17

4.0 ENVIRONMENTAL DETERMINATIONS AND CRM RISK RATING 174.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS 174.2 RECOMMENDED CLIMATE RISK RATING 17

5.0 CONDITIONS AND MITIGATION MEASURES 195.1 CONDITIONS 19

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION 327.0 REVISIONS 33ATTACHMENTS 34ANNEX 1: TEMPLATE FOR SUPPLEMENTAL INITIAL ENVIRONMENTAL EXAMINATIONS

35ANNEX 2: TEMPLATE FOR ENVIRONMENTAL MITIGATION AND MONITORING PLANS 45ANNEX 3: GUIDANCE FOR DEVELOPMENT OF AN INSTITUTIONAL ARRANGEMENT PLAN (IAP) 46ANNEX 4: TEMPLATE FOR ENVIRONMENTAL STATUS REPORTS 50ANNEX 5: GUIDANCE FOR CLIMATE RISK MANAGEMENT SCREENING 57ANNEX 6: CLIMATE RISK MANAGEMENT SUMMARY TABLE 61


1.0 ACTIVITY DESCRIPTION1.1 PURPOSE AND SCOPE OF IEEThe purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), is to provide a preliminary review of the reasonably foreseeable effects on the environment of the USAID interventions described herein and recommend determinations and, as appropriate, conditions, for these activities. Upon approval, these determinations become affirmed, per 22 CFR 216 and BEO Specified Conditions become mandatory obligations of implementation. This RFA-level IEE (herein, “RFA IEE”) also includes the RFA-level Climate Risk Management screening results in accordance with USAID policy (specifically, ADS 201mal).

This RFA IEE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation. This RFA IEE,cleared by FFP Washington, also establishes the requirements for post-award implementing partners (IPs) to develop their own Supplemental IEEs for Mission clearance and outlines other BEO Specified Conditions for implementation and reporting throughout the life of the awards. Environmental compliance at USAID is based on systems-focused environmental reviews that consider the interaction between various systems (environmental, social, political, economic, etc). Procedures outlined here encourage IPs to also use a systems approach in order to understand and work with interconnected complex systems and provide holistic environmental safeguarding and compliance.

In line with the phased approach outlined in the RFA (and described further below), the conditions of this IEE require that environmental and climate risk analysis be undertaken first at the research/collaboration level (Phase 1), and again prior to a systems-driven implementation (Phase 2) when Phase 2 activities are well-defined.

1.2 ACTIVITY OVERVIEWThe Office of Food for Peace (FFP), in the U.S. Agency for International Development’s (USAID) Bureau for Democracy, Conflict, and Humanitarian Assistance (DCHA), is the U.S. Government leader in international food assistance. Through FFP, USAID supports multi-year development (i.e., non-emergency) food security activities to improve and sustain the food and nutrition security of vulnerable populations. Development activities are mandated in the Food for Peace Act and are aligned with the FFP 2016-2025 Food Assistance and Food Security Strategy. These activities work at the individual, household, and systems level to address the underlying causes of chronic food insecurity and strengthen transformative opportunities. USAID also provides emergency food assistance to address needs arising from natural disasters and complex emergencies, which are often characterized by insecurity and population displacement.


Overall, the FFP Strategic Results Framework Strategic Objectives (SOs) and accompanying Intermediate Results (IRs) address key drivers of food insecurity, creating a map of the broad platform of capabilities that FFP and its partners bring to bear in supporting improved food and nutrition security for vulnerable populations. Implementing partners are expected to use innovative approaches to promote environmental risk management to improve and sustain food and nutrition security of vulnerable populations, as articulated in both SO1 and SO2 of the FFP 2016-2025 Food Assistance and Food Security Strategy.

As specified in the Kenya Request for Applications (RFA), Development Food Security Activities in the target FFP geographies6 will contribute to USAID’s FFP Strategy by strengthening community resilience, protecting and enhancing livelihoods, and improving food and nutritional security of vulnerable households.

1.3 ACTIVITY DESCRIPTIONFFP development food security activities in Kenya are intended to sustainably reduce acute malnutrition levels through a systems-level approach that coordinates with and extends beyond individual, household, and community scales. i. To these ends, the FFP office supports the procurement, protection, and distribution of food commodity, including fumigation, as well as a range of program areas and elements. The overarching goal of this multi-sectoral activity is to sustainably reduce levels of acute malnutrition in Kenya’s arid and semi-arid lands (ASALs).

FFP will use a phased approach for the Kenya DFSA(s) to provide implementing partners with the time, support, and access needed to research the local drivers of persistent acute malnutrition and to design interventions that are rooted in evidence, contextually informed, systems focused, and viable for GoK implementation and scale up. The phased approach aims to ensure the activity is learning focused, evidence based, and adaptively managed. The first 18 to 24 months will constitute a research and collaborative design phase (Phase 1), with a subsequent transition to a systems-driven implementation and institutional strengthening phase (Phase 2)7.

Phase 1 activities should directly inform Phase 2; all formative research should be focused on creating a field-ready, field-viable design. The applicants should also consider the use of pilots or other implementation research methods to test innovative approaches and to help tailor planned interventions to each implementation area. Phase 1 will culminate with an internal assessment and partners’ submission of a Phase 2 transition plan, which will outline the findings of

6 Isiolo, Marsabit, Samburu, and Turkana counties7 Please note that the Global Food Safety Partnership (GFSP) is implementing a project to map food safety projects across sub-saharan Africa to build collaboration and encourage capacity building across development practitioners. This project may be of interest to partners, particularly within the system-based focus of the RFA. For more information, see : https://www.gfsp.org/portfolio/african-food-safety-capacity-building-landscape-mapping-assess-effectiveness


Phase 1 and include the Phase 2 implementation plan (i.e. proposed activity design and budget)8

COMMODITY MANAGEMENT: FUMIGATIONFFP makes commodity donations to private voluntary organizations (PVOs) and international organizations (IOs), such as the UN’s World Food Program (WFP). The large majority of FFP commodities are purchased from US farmers and shipped abroad from US ports; however, activities can also distribute locally/regionally procured (LRP) food commodity as long as the use of LRP clearly supports interventions that sustainably reduce vulnerability to food and nutrition insecurity.

In order to prevent spoilage and wasting of food commodity procured by development food security activities, a range of protective measures are implemented in commodity storage warehouses. One common protective measure to prevent loss of commodity from insect, fungal or mammal infestations is fumigation utilizing phosphine gas and/or the application of contact pesticides to warehouse surfaces.

8 FY19 Kenya RFA


OTHER FFP PROGRAM AREAS AND ELEMENTSThe range of program areas and elements which may be supported within these development food security activities are listed below and further described in the FY19 FFP RFA.

TABLE 1: PROGRAM AREAS OR ELEMENTS Commodity FumigationOther FFP Program Areas or Elements Civil society HIV/AIDS Maternal and child health Family planning and reproductive health Water supply and sanitation Environment Climate change – adaptation Climate change - clean energy Nutrition Basic education Social assistance Agriculture Private sector productivity Financial sector Protection, assistance and solutions Disaster readiness


2.0 BASELINE ENVIRONMENTAL INFORMATION2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL)Implementing partners are expected to design their programs to address intervention area-specific biophysical, socioeconomic and cultural conditions, as well as the political and institutional context in which the development food security activities will operate. Applicants are expected to draw from existing USAID or other country-level environmental analyses, including USAID climate change vulnerability and adaptation analyses, (which can be found by searching for Kenya in the Climatelinks resource library), Biodiversity and Tropical Forestry Assessment for Kenya, and Kenya-specific reports.

The following sub-sections provide a brief overview of the baseline climate and environmental information for Kenya. The target FFP geographies that are the focus of this RFA IEE are Isiolo, Marsabit, Samburu, and Turkana counties in Kenya’s arid and semi-arid lands (ASALs). Where region-specific data are unavailable, these sub-sections provide national-level context instead. It is crucial to understand the baseline situation (the existing environmental situation or condition in the absence of USAID activities) in order to understand and measure the impacts, or change from the baseline, caused by the activity.

● Climate Risk ● Key Ecological Habitats ● PERSUAP and Pesticides ● Invasive Species ● Water Resources

CLIMATE RISK The FFP program areas--Isiolo, Marsabit, Samburu, and Turkana counties--fall within Kenya’s desert, semiarid, and tropical savanna climate zones. This landscape primarily comprises arid and semi-arid plains, as well as a few temperate highland areas along the western border of Kenya and south of Lake Turkana. These regions tend to experience high temperatures and low/highly variable rainfall patterns. Although the FFP program areas experience little seasonal temperature variation, the hottest average temperatures occur in February and March, with the coolest temperatures in July and August.9 The highland areas receive the most annual rainfall, at up to 1,000 mm, while the lowland areas have yearly precipitation averages of 200-400mm. Unlike other areas of Kenya, the ASALs typically experience more reliable rainfall during the “short rains” (from October to November/December) than the “long rains” (from March through May/June).

9 USAID. 2018. Climate Risk Profile - Kenya.


Although climate projection data specific to the FFP program areas are scarce, existing climate-related hazards in Isiolo, Marsabit, Samburu, and Turkana include drought, crop and livestock pests and diseases, flooding, waterborne diseases, and restricted dry season water and grazing for livestock. Climate projections for Kenya as a whole indicate that the country will likely experience an increase in average temperatures of 1.2-2.2°C, longer heat waves, more frequent extreme rainfall events, and changes in seasonal precipitation patterns in the coming decades. These stressors are expected to intensify risks to Kenya’s agricultural sector, with adverse impacts on human health and food security. Although livestock production is relatively resilient to climate shocks, these future climatic changes are likely to reduce crop production, increase water scarcity, and produce a warmer and wetter environment more conducive to the transmission of diseases like malaria and dengue fever. Decreased crop production is projected to increase food and nutrition insecurity, which already pose serious risks in the target FFP geographies, where nutrition is highly dependent on livestock and crop production. Acute malnutrition among children under the age of 5 is highest in target FFP geographies such as Marsabit and Samburu (11 percent) and Turkana (23 percent).10

Additional information on the environment and climate baseline, and natural disasters facing the FFP target geographies in Kenya is compiled in the USAID Climate Risks in Food for Peace Geographies – Kenya. All relevant threats should be considered by implementing partners in their Supplemental IEEs.

KEY ECOLOGICAL HABITATSAccording to the Journey to Self-Reliance, FY 2019 Country Roadmap for Kenya, Kenya receives a score of .77 for “Biodiversity and Habitat.” This metric measures the extent of marine protected areas, terrestrial biome protection (weighted for both national and global scarcity), representativeness of protected areas, and whether protected areas cover the ranges and habitats of critical species. As shown in Figure 1, FFP Geographies in Kenya overlap with some of these protected areas.

As stated in this country roadmap, ecosystem services provide vital

10 USAID. 2018. Climate Risks in Food for Peace Geographies - Kenya.


Figure 1. Map of FFP Geographies* and Protected Areas in Kenya; Sources: Political boundaries: Natural Earth (www.NaturalEarthData.com).




benefits to communities, such as water provisioning, carbon sequestration, and flood prevention. Habitat conservation and protection of biodiversity are the foundations of a resilient and sustainable planet.

USAID’s Biodiversity and Tropical Forestry Assessment (FAA) for Kenya 11 states that Kenya is facing significant environmental challenges that are threatening tropical forest conservation and protection of biological diversity. For instance, three of the four counties targeted in the RFA, (of Marsabit and Turkana counties) are experiencing a significant loss of forest biological diversity. Agricultural development and encroachment of pastoral grazing also threaten the Marsabit National Park, whose forest reserve is the region’s main water source. Turkana and Samburu counties are home to woodland-brushland areas that include several national parks and reserves, such as Samburu National Reserve and South Turkana National Reserve. These woodland and brushland areas have experienced a general degradation and loss of ecosystem resiliency in recent years, compounded by overgrazing, illegal charcoal production, bushmeat poaching, and trophy/ivory poaching. Moreover, the populations of several endangered species living in these ecosystems have declined from the 1970s to today: the Grevy’s zebra has decreased from 15,000 to only 2,800, while the black rhinoceros population has steeply dropped from 20,000 to 440.

Turkana and Marsabit counties are also home to the Lake Turkana National Parks, which comprise Sibiloi National Park and two islands on Lake Turkana, Central Island and South Island. Lake Turkana represents an essential habitat for freshwater fisheries, as well as providing water for humans and livestock. Lake Turkana is also a site of cultural and archaeological importance, as fossils of early hominins have been found in the area, making it one of the foremost sites in the world for understanding paleo-environments. However, UNESCO recently added Lake Turkana to its list of endangered World Heritage Sites due to concerns about the threat to its ecosystem from dam projects upstream of the lake and contamination from fertilizers and pesticides.12

Implementing partners should note that Kenya’s Ramsar wetlands are not located in FFP zones. Typically, the presence of a Ramsar wetland indicates a potential need for additional analyses to meet USAID and international standards. However, there may be other wetlands of local or regional importance that should be identified and safeguarded from potential negative impacts of project activities. Wetlands serve as invaluable habitats for numerous species of waterbirds, fish, mammals, reptiles, and invertebrates. Local communities also rely on wetlands as a source of fresh water, irrigation, and food, in addition to serving functions in traditional and religious

11 USAID. 2017. Kenya Biodiversity and Tropical Forestry Assessment.12 News24. 2018. Kenya’s Lake Turkana put on World Heritage danger list .


Figure 1. Map of FFP Geographies* and Protected Areas in Kenya; Sources: Political boundaries: Natural Earth (www.NaturalEarthData.com).

ceremonies. However, long-term challenges such as deforestation, pollution from pesticides, introduction of invasive species, and agricultural activities that degrade water quality threaten the future vitality of wetlands.13

PERSUAP AND PESTICIDESPesticide use in agriculture tends to be infrequent in the ASALs of northern Kenya. Although data on use of pesticides in Samburu and Turkana counties is scarce, research has found that use of inputs such as fertilizers, herbicides, and pesticides for crops like beans, maize, and sorghum in Isiolo County were very low. Local farmers in Isiolo use pesticides like Thiodan, Karate, Duduthrin, Bestox, Actellic super, and Sherpa plus to protect their green gram crops from key pests, although they have also developed traditional strategies such as the use of wood ash and animal dung to manage pests and diseases.14 In addition, only about 1 percent of households in Marsabit County use storage pesticides, only just 4 percent use herbicides. Access to fertilizers, herbicides, and pesticides is a challenge in Marsabit due to the small number of suppliers and the high transaction costs caused by poor road infrastructure.15 However, while pesticide use remains low in these areas, analysis has shown that pesticide use still poses risks to ecosystems, pest and disease resistance, and the safety of crops and farmers.

There is greater use and knowledge of pesticides among commercial farmers than subsistence farmers in the northern ASALs, but there is a general unfamiliarity across farming populations about the dangers of poor pesticide management.16 As the ASALs experience a growing population and intensification of farming that are likely to increase demand for pesticide use, this lack of awareness compounds the risk that improperly handled pesticides may pollute the air, water sources, and soil, harming natural habitats and potentially endangering human health.17

INVASIVE SPECIESInvasive species are highly adaptable to rising temperatures and variable climate conditions.18 Some initiatives have even promoted certain invasive species because of these very characteristics, to the detriment of land productivity, biodiversity and ecosystem function. Guidance from the Bureau for Democracy, Conflict, and Humanitarian Assistance (DCHA) Environmental Officer specifically prohibits USAID support for promotion of any invasive species. More than 100 non-native species currently pose threats to native plants and agricultural production throughout

13 The Ramsar Convention on Wetlands. 2012. The Annotated Ramsar List: Kenya. 14 Kenya Ministry of Agriculture, Livestock and Fisheries. 2017. Climate Risk Profile for Isiolo County.15 Kenya Ministry of Agriculture, Livestock and Fisheries. 2017. Climate Risk Profile for Marsabit County . 16 USAID. 2018. Climate Risks in Food for Peace Geographies - Kenya.17 Government of Kenya. 2010. Pest management plan for Kenya ASALs SWAp Project.18 USAID. 2018. Climate Risks in Food for Peace Geographies - Kenya.


Kenya. The following are some examples of species that have become invasive in the FFP zones:

● Prosopis juliflora (Marsabit, Samburu, and Turkana counties): Small, fast-growing, drought-resistant, evergreen shrub or tree with deep tap roots; grows in arid and semi-arid environments, forms dense stands and encroaches on irrigation schemes, farmland, and pastureland.1920

● Acacia reficiens (Isiolo, Marsabit, and Samburu counties): Perennial, deciduous shrub or tree; spreads quickly in areas with highly degraded soils; releases a chemical that displaces other species and suppresses growth of grasses.2122

● Lantana camara (Marsabit and Samburu counties)23: Perennial, flowering shrub, grows to 6 feet or more in height24; resilient to dry conditions and spreads rapidly to form dense thickets in pastures and natural and degraded areas.

19 P. Maundu, S. Kibet, Y. Morimoto, M. Imbumi, & R. Adeka. 2011. Impact of Prosopis juliflora on Kenya’s semi-arid and arid ecosystems and local livelihoods. 20 Center for Agricultural Biosciences International. 2012. Action Plan for Implementing the Convention on Biological Diversity’s Programme of Work on Protected Areas.21 Namibia Biodiversity Database. 2019. Acacia reficiens.22 Servir Global. 2018. Invading Acacia Threatens Unique Northern Kenya Ecosystem.23 Shadrack Kavilu. 2010. Invasive Species a Threat to Africa’s Game Reserves.24 University of Florida Center for Aquatic and Invasive Plans. 2018. Latana camara.


WATER RESOURCESAlthough Kenya has made progress in increasing availability of improved water services in recent years, access has not kept pace with population growth. Thirty-nine percent of Kenya’s population lack access to improved water sources such as wells, while 70 percent still use unimproved sanitation solutions.25 Outbreaks of waterborne diseases such as typhoid, cholera, bilharzia, and diarrhea are expected to increase as the northern ASALs experience more heavy rainfall events. This poses a particularly serious danger to the region, where only 10-30 percent of people have access to improved water sources. Research has found that only 7 percent of Turkana County’s population have access to improved sanitation, and E. coli contamination was found in 100 percent of sampled boreholes, 91 percent of taps, 63 percent of dams/pans and 58 percent of wells.26

While accurate statistics on the quality of groundwater in Kenya are generally lacking, a report by the International Water Management Institute found that water sources in the country’s coastal regions tend to exhibit some salinization due to saltwater intrusion inland. Water quality in the eastern and northeastern provinces is also poor, and most shallow wells in these areas are unprotected and may therefore have significant levels of bacterial contamination.

Moreover, USAID classifies Kenya as one of the most water-scarce countries in the world.27 Per capita water availability in Kenya is in the lowest either percent of all countries, at just 523 cubic meters (m3), well below the internationally accepted minimum standard of 1,000m3. Availability is projected to decrease to as low as 293 by 2050, further exacerbating water security concerns for both people and agriculture.28

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS, ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS

SUB-SAHARAN AFRICA EIA PROCEDURESEnvironmental impact assessment, or EIA as it is known, is a procedures for evaluating the impact proposed activities may have on the environment. In recent years, significant strides have been made to build a legal foundation for EIAs in Sub-Saharan Africa. Whereas EIAs typically used to be carried out only to meet requirements of foreign donors, they are now mandated in twenty-two Sub-Saharan countries, as an important element of domestic environmental law, and policy. IPs for Kenya are expected to understand and document their compliance with local EIA regulations in their Supplemental IEEs.

KENYA REGULATORY STRUCTURE25 USAID. Accessed 2018. Global Water and Development.26 USAID. 2018. Climate Risks in Food for Peace Geographies - Kenya.27 USAID. 2018. Kenya Water, Sanitation, and Hygiene.28 USAID. 2018. Climate Risks in Food for Peace Geographies - Kenya.


The Kenyan Constitution of 2010 establishes the country’s commitment to environmental conservation, stating that all Kenyan citizens have “the right to a clean and healthy environment,” which includes the right “to have the environment protected for the benefit of present and future generations…” Moreover, Article 69 of the Constitution lays out the State’s environmental protection responsibilities, including the obligation to ensure sustainable use of natural resources, maintain a tree cover of at least 10 percent of the country’s land area, and protect biological diversity.29

In addition to the Constitution, Kenya enacted the Environmental Management and Co-ordination Act (EMCA) No. 8 of 1999 (amended in 2015) as the country’s broad framework environmental legislation. The EMCA is the primary legal reference on all matters related to the regulation, management, and utilization of natural resources. In addition, the EMCA establishes the National Environment Council, which is responsible for formulating national environmental policies and goals for the protection of the environment.30

Kenya is also a member on several international agreements, treaties and conventions such as: Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), United Nations Framework Convention on Climate Change (UNFCCC), and Ramsar Convention on Wetlands of International Importance, just to name a few. More detailed information can be found in the Biodiversity and Tropical Forestry Assessment for Kenya.

In addition, the Second National Communication of Kenya on Climate Change to the UNFCCC, released in 2015, highlights climate mitigation commitments of the country, as well as sector-specific climate risks and adaptation measures.

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL AND CLIMATE RISKThis section provides an analysis of the environmental risk of commodity fumigation in FFP activities, (given that most FFP activities will use commodity fumigation to prevent the loss of food commodities), as well as the anticipated climate risks to fumigation activities. While the impacts of commodity fumigation are well understood across the FFP landscape, the environmental impacts and climate risks of other FFP activities will depend on the specific context in which activities are implemented. Further, FFP activities are typically undefined at the RFA level, which makes the evaluation of potential environmental impacts and climate risks difficult. Therefore, analyses of the environmental impacts and climate risks of non-fumigation activities need to be undertaken in the Supplemental IEE.

3.1 ENVIRONMENTAL IMPACTS OF COMMODITY FUMIGATIONMost FFP activities will carry out the storage and protection of commodities, either as US in-kind food assistance or as locally procured food commodity. To prevent the 29 Republic of Kenya. 2010. The Constitution of Kenya.30 Republic of Kenya. 2012. Environmental Management and Co-ordination Act.


loss of food commodity from pest infestations during storage, it is common practice to perform periodic fumigation of warehouses and/or the application of contact pesticides to warehouse surfaces.

As mentioned in the Fumigation PEA, impacts of commodity fumigation must be considered, including:

● Use of the fumigant aluminum phosphide, and to a lesser extent magnesium phosphide, can potentially affect the health of applicators and other on-site workers and visitors.

● Use of the fumigant phosphine gas can affect the health of residents near warehouses being fumigated.

● Fumigation residuals could affect water quality, soil, and non-target organisms.

● Poor practices in transport, storage, application, and disposal of fumigants are a concern for human health.

● Improper disposal practices of rodents and birds killed by phosphine gas could affect human health.

● Phosphine may not completely control fungal contamination.

In addition, it is a USAID agency commitment that activities consider the procurement or promotion of pesticides as a last resort within an Integrated Pest Management (IPM) framework (see USAID Special Topic Presentation on Pesticides). Whichever their intended use may be, pesticides are potent killing agents and their use poses intrinsic dangers to applicators, households, communities and the environment. These risks include, but are not limited to:

● Use of chemical, non-organic compound-based, and biological or botanical-based pesticides can potentially affect the health of applicators, on-site workers and visitors.

● Poor practices in the transport, storage, application, and disposal of pesticides and pesticide containers are a concern for human and environmental health.

● Pesticides can negatively affect and/or eliminate non-target organisms in the environment, (i.e. predatory insects and pollinators, microorganisms beneficial to soil health, aquatic organisms, etc.) thereby altering ecological food webs and potentially causing detriment to agricultural production systems.


● Chemical pesticides can contaminate surface and groundwater water, soils, and can bioaccumulate in surrounding ecosystems and organisms, posing a concern for health.

● Misuse or overuse of pesticides can result in pesticide resistance.

TABLE 2. POTENTIAL ENVIRONMENTAL IMPACTS, AND CLIMATE RISKS, OF COMMODITY FUMIGATION

Commodity Fumigation

Potential environmental and social impacts Potential climate risks

Warehouse treatment of bagged and bulk commodity

● Negative health impacts to applicators and on-site workers and visitors (including transporters)

● Negative health impacts of residents near fumigation sites

● Negative impacts to water quality, soil, and non-target organisms if fumigant disperses from the site

● Negative health impacts due to poor solid waste management (such as improper disposal of dead birds and rodents killed by fumigants) of fumigation residues/byproducts

● Need for ancillary treatment of fungal diseases as Phosphine may not be effective in control of fungal contamination

Certified applicators unwilling to use personal protective equipment due to increased temperatures.

Warehouses where commodities are stored are in locations threatened by extreme weather, or in flood zones.

Increased temperatures and changes in rainfall patterns, changes occurrence of pests and pathogens and therefore fumigation requirements.


3.2 CLIMATE RISKS TO COMMODITY FUMIGATION As noted in Section 2, Kenya will experience increasing temperatures. The country will also likely see an increase in frequency and intensity of heavy rainfall events, leading to increased flooding. Additionally, there may be an increase in duration of both heat waves and dry spells. The climate risks expected in Kenya could impact fumigation by changing herbivore and pathogen range and occurrence, which should also be considered during fumigation, and threatening the effectiveness of fumigation storage effectiveness.

3.3 OTHER FFP PROGRAM AREAS AND ELEMENTSThis RFA IEE cannot determine the reasonably foreseeable potential environmental impacts and climate risks of interventions within the FFP Program Areas and Elements described in Section 1.3, as the scope and technical approach of these interventions have not yet been defined. These interventions will be refined and analyzed in Supplemental IEEs.

4.0 ENVIRONMENTAL DETERMINATIONS AND CRM RISK RATING 4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS31

A Positive Determination, pursuant to 22 CFR 216.3(b)(l)(ii), is recommended for all commodity fumigation activities that use a restricted use pesticide, as registered by the USEPA. Please see additional information in Section 5 under Condition 6b.

A Deferral is recommended for all other activity interventions that are not yet well defined in scope or technical approach pursuant to 22 CFR 216.3(a)(7)(iv). The Deferral for these interventions, or FFP program elements, must be resolved in the post-award Supplemental IEE, in which each intervention will be assigned a threshold determination: Categorical Exclusion, Negative Determination with Conditions or Positive Determination.

4.2 RECOMMENDED CLIMATE RISK RATINGThe recommended climate risk rating for commodity fumigation is based on the anticipated likelihood and severity of climate risk, per 201mal. Low, moderate and high risk ratings were identified based on likely climate risks to commodity fumigation.

The following table summarizes the recommended determinations based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22 CFR 216.

31 A “determination” is a classification of likely environmental impacts attached to a particular USAID action. A “Categorical Exclusion” determination indicates unlikely negative environmental impacts. A “Negative Determination” indicates unlikely negative environmental impacts with appropriate mitigative action. A “Positive Determination” indicates likely significant environmental impacts, and triggers the process for development of a full environmental impact assessment.



TABLE 3: ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

Illustrative Interventions

22 CFR 216 Environmental Determination

Climate Risk Rating

Commodity FumigationPositive Determination Low, moderate, and high (see Annex 6)

Other FFP Program Areas and Elements Deferral Deferral


5.0 CONDITIONS AND MITIGATION MEASURES5.1 CONDITIONSFor applicants, USAID FFP environmental compliance at the time of activity design will be met through adherence to both 1) this RFA IEE and 2) completion of a stand-alone, Supplemental IEE, only upon USAID’s indication of an intent to award. In line with the phased approach of this RFA, the Supplemental IEE will be completed in two phases: the first draft of the IEE will cover activities during the research and collaborative design phase (Phase 1) and will be refined into a final draft prior to the systems-driven implementation and institutional strengthening phase (Phase 2) (see Table 4 below). Once the final Supplemental IEE, including the Environmental Mitigation and Monitoring Plan (EMMP), CRM screening, and IAP (including attendant budget), is finalized and approved by the DCHA BEO, the IEE is to be used to guide activity implementation. All mitigation measures contained in the Supplemental IEE must be implemented and monitored for effectiveness in reducing potential environmental impacts resulting from interventions.

The following 8 conditions describe awardees’ environmental compliance, mitigation, monitoring and evaluation responsibilities throughout the life of award (LOA). Figure 1 below provides a visual schematic of the requirements over LOA.

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

Figure 2. Overarching Environmental Compliance Flowchart for FFP Activities

PRE-AWARD STAGECONDITION 1: APPLICANT TO SUBMIT ENVIRONMENTAL SAFEGUARDS PLANUSAID requires analyses which consider environmental risks across the Agency, using a set of defined procedures to meet USAID environmental requirements.


Applicants are expected to design innovative approaches to promote environmental and climate risk management to improve and sustain food and nutrition security of vulnerable populations, as articulated in both SO1 and SO2 of the FFP 2016-2025 Food Assistance and Food Security Strategy. Applicants must summarize these environmental approaches into a four-page Environmental Safeguards Plan.

This plan must summarize:

1. How strategies to reduce both environmental impacts of the activity and climate risks to the activity have been integrated into activity design;

2. How funds for environmental and climate risk management have been allocated in the detailed/comprehensive budgets and described in the budget narrative;

3. How staffing for oversight of environmental compliance requirements will be carried out over the life of the activity; and

4. How outcomes of the EMMP will inform performance as monitored through the Logical Framework and Indicator Performance Tracking Tables (IPTT) in M&E systems.

In line with the expectations of Phase I activities as outlined in the RFA, this Environmental Safeguards Plan should how consider potential issues (proximity to sensitive ecological areas like Lake Turkana and others protected areas, poor soil quality, degraded water resources, invasive species, poor seed or pesticide quality, climate shocks, etc.) might impact the design strategy in Phase 1.

POST-AWARD STAGECONDITION 2: AWARDEE TO DEVELOP SUPPLEMENTAL IEE FOR MISSION AND WASHINGTON CLEARANCEIEE

Upon receipt of the FFP award, implementing partners will be required to develop a Supplemental IEE32 specific to the award. The Supplemental IEE will describe the environmental impact analysis for all Phase 1 activities (i.e. formative and implementation research) in the project’s zone of influence, within the FFP geographies described in the RFA. In short, the Supplemental IEE must 1) summarize the technical design, 2) describe baseline environmental conditions in the FFP zones of influence 3) identify all reasonably foreseeable environmental impacts of interventions, and 4) recommend sound mitigation measures to prevent, reduce or compensate for environmental impacts.

Timing: Implementing partners must develop a draft of the IEE (covering Phase 1 activities) no later than 14 weeks following the Post-Award Conferences. Prior to the M&E and Baseline Workshop, partners should revise the IEE to cover Phase 2 activities, (with the option to submit earlier for informal review) for use in 32 A word versions of the Supplemental IEE template can be found at a Google drive here: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8



coordination of the EMMP and performance M&E systems. Awardees will then finalize the IEE after the Phase 1 Culmination Workshop and submit the IEE, EMMP, CRM screening, and IAP within 8 weeks. The timing is further outlined in Table 4 below.

TABLE 4. PHASE 1 OF THE PHASED APPROACH FOR KENYA – KEY COLLABORATION EVENTS33 WITH RELEVANT IEE ACTIONS.

33 As described in the FY19 Kenya RFA


Phased Approach: FFP will use a phased approach, as described in the FY 19 Kenya RFA for the Kenya Development Food Security Activities (DFSAs) that will provide IPs with the time and support needed to research the local drivers of persistent acute malnutrition and design interventions grounded in the evidence supported by that research. This approach will consist of two phases: The first phase (approximately 18-24 months), during which awardees carry out pre-implementation activities, such as research, community consultation and local engagement, preparation for implementation, piloting of new approaches, refining of the Theory of Change, and designing of activities. The second phase, involving implementation of all programmatic interventions, begins after the end of Phase 1. Implementation of the full suite of programmatic interventions begins after the end of Phase 1 pending submission and FFP’s approval of the transition plan, which will include the revised theory of change and updated program documents. It is expected that during implementation, as a matter of strong adaptive management and continued program quality improvement, awardees will continue with efforts to close knowledge gaps, refine planning, test and pilot innovative approaches, update the theory of change and continue stakeholder engagement and coordination with other relevant actors. After an external evaluation in year four, the Phased Approach will allow highly successful activities to be extended and continue for up to five years past the

Key Collaboration Event Timing IEE Action

Post-Award Conferences (DC)

Immediately after award

● BEO office presents overview of RFA IEE to awardee HQ staff

● Awardee submits draft Supplemental IEE covering Phase 1 activities (i.e. formative and implementation research) to USAID no later than 14 weeks after post-award conference

Kickoff Meetings(In Country)

Within weeks of award after discussion and agreement with IPs

● FFP field reviews the RFA IEE conditions with awardee

Monthly Technical Steering Committee Meetings (VTC)

Monthly ● AOR provides BEO Office notes from monthly meetings

Gender Consultation(In Country)

Approximately ten weeks after award

● N/A

Technical Team Field Visits (as needed)

Approximately 13 weeks after award

● Technical team provide BEO Office notes from field visits

Phase I Inception Workshop (In Country)

Approximately 14 weeks after award

● BEO office presents environmental and CRM compliance process

M&E and Baseline Workshop(In Country)

Approximately 12-14 months after award

● BEO office presents environmental and CRM compliance process

● Awardee revises Phase 1 Supplemental IEE to reflect new Phase II activities (option to submit to USAID for informal review prior to M&E and baseline Workshop

Phase I Culmination Workshop

Approximately 18 months after award

● Awardee submits a revised Supplemental IEE covering Phase 2 activities to USAID no later than eight weeks after Phase I Culmination Workshop with Phase 2 transition plan

Chief of Party - Phase 2 Transition Presentations

Approximately 20-24 months after

● Awardee provides Transition Plan to BEO Office for review


Key Collaboration Event Timing IEE Action

(In Country) award of environment and climate integration

● Awardee presents on budget and staffing for environmental monitoring of the IEE

There are important resources that partners can consult when developing Supplemental IEEs:

● For a general introduction on how to develop an IEE, consult the USAID IEE Assistant.34

● Partners are advised to consult previous Supplemental IEEs to research common environmental concerns and solutions among FFP activities globally. Partners can utilize the USAID Environmental Compliance Database to search for USAID-approved IEEs.

● For technical guidance on environmentally sound design and management for USAID development activities, consult the USAID Sector Environmental Guidelines.

IEE Amendments

IEE Amendments: In the event that any new proposed interventions differ substantially from the type and/or agroecological zone of interventions described in a Supplemental IEE, an IEE Amendment (IEE-A) will be developed, including a revised EMMP (and potentially revised IAP and CRM screening, as needed). Amendments must be sent to FFP and reviewed for approval by the DCHA/BEO prior to implementation. Some of the possible triggers for an IEE-A include, but are not limited to: modified or new interventions, new geographic zone, cost extension, and/or significant time extension.

Pursuant to 22 CFR 216.2(b), activities involving international disaster assistance or other emergency circumstances may be Exempt from these procedures. Emergency activities with Agreement Officer approval may be Exempt from environmental review, such as the transfer of food commodities pursuant to 22 CFR 211.

EMMP revisions during the course of implementation, such as fine-tuning mitigation measures or including additional analysis for unexpected impacts, are encouraged as part of any activity’s sound adaptive environmental management. It is important to note, such EMMP modifications do not require an IEE amendment or USAID approval. However, all EMMP changes and their rationale, should be reported in subsequent ESRs.EMMP34 Provides useful overall process information, but templates are out of date and should not be used.


As an annex to all Supplemental IEEs, FFP applicants must complete an EMMP35 which serves as the implementation and monitoring plan for all required 22 CFR 216 compliance actions to be taken by a given activity. This RFA IEE provides a template for the EMMP in the annexes. Detailed guidance and best-practice considerations for the development of the EMMP will be available on the USAID Environmental Procedures Website36 and in the Environmental Mitigation and Monitoring Plan Factsheet. The effectiveness of the individual compliance actions (mitigation measures) to prevent or reduce environmental impacts must be monitored periodically throughout the life of the activity. The results of this monitoring should be described in the annual ESR. See information below.CRM ScreeningUpon receipt of the award, the partners will develop a Climate Risk Management (CRM) screening for all activities. CRM is the process of assessing, addressing, and adaptively managing climate risks that may impact the ability of USAID programs to achieve their objectives. It is recommended that Climate Risk Management screening begin with the Supplemental IEE under this RFA, with the exception of fumigation activities (See Annexes 5 & 6 for more details). Currently, the activity interventions for this RFA are not well defined in scope or technical approach, and therefore it is appropriate to begin Climate Risk Management screening when they are better defined, at the Activity-level, pursuant to Climate Risk Management for Projects and Activities. A Mandatory Reference for ADS 201. It is likely that many of these interventions will have high and moderate climate risks during implementation. When high and moderate climate risks are identified, Climate Risk Management screening for these activities must be resolved in the post-award Supplemental IEE, in which climate risks, and opportunities to integrate climate into programming, will be identified and addressed as outlined by USAID policy and FFP Climate Risk Management guidance (found in Annex 5 and also on the Climatelinks Climate Risk Management website). Furthermore, Climate Risk Profiles and Climate Risks in Food for Peace Geographies for Kenya have been developed to assist with CRM screening under this RFA-IEE:

● Climate Risks in Food for Peace Geographies - Kenya

35 A word versions of the EMMP template can be found at a Google drive here: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS836 This website is under construction, and will be available soon.



https://www.usaid.gov/environmental-procedures

https://www.usaid.gov/environmental-procedures


IAP

The Institutional Arrangement Plan (IAP)37, is a useful tool to help frame the budget and staffing needs for IEE implementation. This is not a new requirement, but rather a new framing for an existing need. The IAP describes the, implementing partner capacity for fulfilling the implementation conditions required by the Supplemental IEE, EMMP and CRM screening. The IAP is submitted with the Supplemental IEE, and later updated with the annual ESR38. A budget for the implementation of the IEE must be transparently demonstrated in the Detailed and Comprehensive Budget and Budget Narrative for the award. The budget includes provisions for:

● internal staffing● technical support● training ● monitoring/reporting● pesticide expertise● environmental assessments, as needed

An IAP template can be found in Annex 3 and at the following Google Drive: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8

Budget Guidance. The budget for environmental compliance must not exceed the Total Estimated Cost (TEC) of the multi-year activity. Rather this compliance budget must be allocated from within the award TEC. Failure to do so in a transparent manner, will result in delays. The budgeting for environmental compliance is to be reviewed in the beginning of the activity, and annually with the Pipeline and Resource Estimate Proposals (PREPs39). Refer to the USAID Environmental Budgeting Toolkit for step-by-step guidance for both budget developers and USAID budget reviewers. While the BEO can provide guidance on budgeting for environmental compliance, only the AOR can authorize budget commitments.

37 A word versions of the IAP template can be found at a Google drive here: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS838 *The ESR is similar to the Environmental Mitigation and Monitoring Report (EMMR) used elsewhere in USAID. However, the ESR meets both purposes of reporting and budget planning for environmental compliance.39 The PREP describes an awardee's resource needs and interventions for a specific upcoming period of time agreed to by the partner and the Agreement Officer’s Representative.




Figure 3: Developing Activity Budgets for Environmental Compliance Requirements.Source: Adapted from Environmental Compliance Budgeting Toolkit, p. 5.

*Note: It may be possible to combine Steps 3 and 4 into a single step, depending on the particular budgeting process. It is shown here as two separate steps for greatest clarity.

The BEO Issues Letter

After reviewing IP inputs, both post-award and throughout the project life-cycle (IEEs, ESRs, PERSUAPs, EAs, etc.), the BEO will prepare an “Issues Letter” highlighting questions, concerns, or changes that should be made to the document before it can receive final BEO clearance. IPs will need to respond to the Issues Letter and revise their documentation accordingly before re-submitting for BEO clearance. Upon final BEO and Climate Integration Lead (CIL) approval, all environmental compliance documentation is subsequently shared with the implementing partner and uploaded to the publicly accessible Environmental Compliance Database. Supplemental IEEs must be approved by the USAID DCHA BEO and CIL prior to the implementation of medium-risk interventions (i.e.,

classified as a Negative Determination with Conditions as per 22 CFR 216).

CONDITION 3: IMPLEMENT ENVIRONMENTAL MONITORING REQUIREMENTS


Drinking Water Quality-- Requirements and Additional Guidance

Per USAID regulations, implementing partners are required to monitor drinking water for arsenic and fecal coliform levels in the case of new construction or rehabilitation of drinking water infrastructure (Guidance Cable State 98 108651). USAID is currently piloting a guidance tool for water quality, termed Water Quality Assurance Plans (WQAPs). This provides a template for partners to articulate a clear plan for water quality assurance, as well as establish a plan of action if contamination is identified. Testing alone is not sufficient to address sources of contamination. Additional support for improved water supply systems can be found in the Visual Field Guide which includes simple photo-rich monitoring tools. Water quality and quantity assurance is important for food security in Kenya. If DFSA applicants intend to directly or indirectly support the provision of potable water, partners should submit a plan for water quality assurance either through the WQAP or by incorporating the needed information in the EMMP.

Given the significant resource and capacity constraints within many FFP host countries, partners using the WQAP are strongly encouraged to tailor or modify this guidance to fit the context and to reflect a realistic plan for assuring water quality. For example, if host government water quality labs are unavailable, partners could provide a plan for field monitoring of water quality that still strives to engage and build capacity of local officials or private operators.

Environmental monitoring is crucial to ensuring that environmental compliance and climate risk management requirements are being successfully implemented. Partners can use environmental monitoring systems and site visits (described below) to implement monitoring requirements. These methods should be incorporated into the project’s wider M&E systems.

3A. DEVELOP ENVIRONMENTAL MONITORING SYSTEMSEMMP Tools for Field Monitoring: Implementing Partners can develop EMMP tools (such as checklists) to assist in the integration of environmental management issues in the planning, design, implementation and monitoring phases. EMMP tools can be designed for rapid environmental diagnostic exercises, which aim to identify site-specific environmental conditions that may lend to the generation of localized impacts. This analysis can be used to determine the most appropriate environmental management strategies on a site-specific basis. For monitoring purposes, tools can also be designed to facilitate the data collection and monitoring of EMMP indicators. The environmental monitoring system that the partners use or develop should be described in the IAP, mentioned above under Condition 2.

One such example of site field monitoring tools are the Visual Field Guides, which are intended to support field monitoring of select interventions by development professionals, including those who are not environmental specialists. They are photo-based, simple yes-no checklists that identify the most typical, significant environmental design and management considerations by development sector.

Another example of an environmental monitoring checklist system is the Go Green Strategy (GGS). This scorecard system provides environmental management information in a simple Yes/No checklist, which can be used as a monthly monitoring tool by field agents. USAID conducted a more detailed assessment of the GGS through a field assessment, as described in the “Examination of Environmental Foundations for Program Design Environmental Compliance Review and Go Green Strategy Snapshot”.

A new tool for use on phones, tablets and browsers is the Nexxus Environmental Assessment Tool (NEAT+). NEAT+ is based in Kobo Toolbox, open-source software for project level assessment of the current sensitivity of the local environment, highlighting any underlying vulnerabilities. NEAT+ is hosted on EHAConnect which is a portal to help environmental actors engage in the disaster space and humanitarians develop more resilient emergency management systems. The NEAT was developed with a broad range of humanitarian and environmental stakeholders as part of the Joint Initiative for the Coordination of Assessments for Environment in Humanitarian Action.

USAID Environmental Compliance Site Visits: As required by ADS 204.5.4, the AOR, in consultation with FFP activities, FFP Managers, Mission Environmental Officers (MEO) and/or the DCHA/BEO will actively monitor and evaluate whether environmental consequences unforeseen under interventions covered by this


current RFA IEE, and the Supplemental IEEs, arise during implementation and modify or end interventions as appropriate.

3B. INTEGRATE ENVIRONMENTAL MONITORING, INCLUDING CLIMATE RISKS, INTO M&E SYSTEMSA key component of environmental safeguards for USAID activities is to ensure the inclusion of climate risk and environmental considerations into activity performance monitoring systems. For FFP, to promote ongoing safeguards for environmental goods and services while achieving food assistance and security gains, applicants will need to integrate environmental considerations into the overall activity M&E systems.

The M&E workshops, which will be held 12-14 months after the Kenya DFSAs are awarded, are designed to convey M&E requirements and to strengthen awardees’ Logical Frameworks and Indicator Performance Tracking Tables (IPTTs). During these workshops, awardees have an opportunity to work with M&E experts to coordinate the IPTT with the EMMP.

Implementing Partners can also visit the Food and Nutrition Technical Assistance (FANTA) III website for additional tools that can assist with environmental monitoring, such as indicator guides. For more than 15 years, the FANTA project provided support to USAID in the development of methods and best practice guidance to support rigorous M&E systems.

As described in the Policy and Guidance for Monitoring, Evaluation, and Reporting of Development Food Security Activities, awardees may make other additions to the Performance Indicator Reference Sheet (PIRS) to clarify the use of a FFP or Mission indicator in the activity’s M&E Plan. For example, text may be added to the Rationale section to identify the indicator as part of the activity’s EMMP and explain how the indicator is environmentally sensitive to the activity context (please see the Recommended Performance Indicator Reference Sheet).

Clarifications inserted into the PIRSs, like those described above, do not ‘change’ the FFP or Mission indicator; they simply add more information about how the indicator will be collected and which activities beneficiaries or outputs will be considered.

CONDITION 4: REPORT ON USAID ENVIRONMENTAL COMPLIANCEReporting on environmental compliance throughout the programming lifecycle assists FFP in understanding whether the DFSA is making adequate progress toward achieving results from the prescribed environmental safeguards and compliance with USAID regulations. Implementing partners report on USAID environmental compliance by developing Environmental Status Reports (ESRs) and integrating environmental and climate reporting into Annual Results Reports (ARRs).

Environmental Status Report (ESR)


ESRs40 must be completed by all FFP awardees on an annual basis starting in Phase II, to report on progress toward achieving environmental compliance. ESRs must be submitted along with the M&E plans in January, or at least three (3) months before the anticipated PREP submission by the partners.

The ESR is designed to:

1. Document environmental safeguard staffing and budget for the upcoming implementation year; and

2. Identify progress towards achieving environmental compliance and reducing climate risks, including a report out on EMMP monitoring.

The ESR Guidance (see template41 in Annex 4 and guidance on the overall process here) provides instruction to awardees on what information must be included in the ESR.

40 Also known as Environmental Mitigation and Monitoring Reports (EMMRs) elsewhere in USAID.41 A word version of the ESR template can also be found at the following Google Site: and at the following Google Drive: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8


Mission Requirements for Sub-project Review

The Environmental Review Form (ERF) and Environmental Review Report (ERR)* were developed by the USAID Africa Bureau to enhance environmental management and oversight of USAID programming for sub-projects that may not be well-defined at the IEE stage.

As noted in the ERF/ERR Form and Instructions, the BEO will not clear an IEE or EA that authorizes use of the ERF unless ALL of the following are true:

1. the general nature or potential scope of the activities for which the ERF will be used are known at the time the IEE is written (e.g. small infrastructure rehabilitation, training and outreach for a specified purpose, etc.).

2. these activities will be executed under a grant or subproject component of a parent project/program. The ERF cannot be used in lieu of a request for categorical exclusion, IEE or IEE amendment when new activities/components are to be added to existing projects, programs or sector portfolios.

3. of their general nature, foreseeable adverse environmental impacts are small or easily controllable with basic mitigation techniques that can be successfully implemented by field staff.

4. of their general nature, the activities are NOT large-scale.**

While many missions in Africa have been using the ERF/ERR for years, the application of ERF/ERRs to DCHA Bureau programs is new. As such, all ERF/ERRs for FFP programs must also be submitted to the BEO for DCHA, for information purposes only. The BEO will not be providing formal clearance at this time. However, if any significant issues are identified during BEO review, a resolution will be identified through AOR and MEO engagement.


* Note that the Environmental Screening Form (ESF) is an older process that has been updated and replaced by ERF/ERRs. The BEO is working with MEOs and FFP projects in the region to ensure that the most recent templates are being used.**Refer to the ERF Instructions for definition of scale

Annual Results Reports (ARRs)

Awardees are required to submit an ARR for each FY during which interventions were implemented, regardless of when funding or food assistance commodities were provided. An ARR describes the performance results of interventions implemented during the reporting FY. The ARR should include the results of IPTT environmental and climate change indicators, environmental monitoring reports, assessments, action plans, and/or case studies related to the integration of environmental safeguards and climate change considerations. Please see the FFP ARR Guidance for more information.

CONDITION 5: DEVELOP AN ENVIRONMENTAL ASSESSMENT FOR ANY ACTIONS WITH POTENTIAL FOR SIGNIFICANT IMPACT TO ECOLOGICAL HABITATS, AS DETERMINED BY USAID.Increasingly, FFP partners have been responding to the need to develop more significant physical infrastructure to meet food security demands. For activities with potential for significant environmental effect, such as encroachment or impacts to protected areas or sensitive ecological habitats, like Lake Turkana, USAID may require partners to complete a full environmental impact assessment.

A Positive Determination, pursuant to 22 CFR 216.3(a)(2)(iii) or 22 CFR 216.5, may arise if an interventions determined as a Deferral by this RFA IEE is later identified as having the potential to cause significant environmental effect. Interventions that receive a Positive Determination will require further analysis, such as a Scoping Statement and Environmental Assessment. The following classes of actions have been determined generally to have a significant effect:

● Programs of river basin development;● Irrigation or water management projects, including dams and impoundments;● Agricultural land leveling;● Drainage projects;● Large scale agricultural mechanization;● New lands development;● Resettlement projects;● Penetration road building or road improvement projects;● Powerplants;● Industrial plants;● Potable water and sewerage projects other than those that are small-scale.

Additionally, if the proposed activity will have the effect of jeopardizing an endangered or threatened species or of adversely modifying its critical habitat, the Threshold Decision is a Positive Determination.


CONDITION 6: PLAN FOR A PESTICIDE EVALUATION REPORT AND SAFE USE ACTION PLAN (PERSUAP)

6A. PERSUAPS FOR PESTICIDE USE (E.G. AGRICULTURE, LIVESTOCK, PUBLIC HEALTH, CONSTRUCTION)FFP partners must take note that pursuant to 22 CFR 216.3(b), in the event that any interventions include the promotion, procurement, transport, storage or disposal of pesticides for agricultural or livestock interventions, vector control interventions, or construction material treatment, a PERSUAP for proposed pesticides must be approved by the DCHA/BEO prior to the commencement of these interventions. PERSUAPs should be submitted with Supplemental IEEs (or as amendments to Supplemental IEEs). For more information on USAID environmental compliance policy requirements related to pesticides and PERSUAPs, see this Special Topic Presentation.

Tiering off of Existing Mission PERSUAPs As soon as interventions in which the procurement or promotion of pesticides are anticipated, it is recommended that awardees contact their Mission Environmental Officer (MEO) to inquire whether an existing PERSUAP has been developed in the country or region that provides the requisite approval and guidance for the use of a particular pesticide or series of pesticides42. FFP encourages its awardees to tier off existing USAID analyses when possible, thereby reducing the need to carry out new and potentially redundant analyses, yet allowing for the appropriate consideration of the specific needs and context of each development food security activities. In this case, the FFP activity will need to develop a Safe Use Action Plan (SUAP). The SUAP provides a succinct, definitive stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also assigns responsibilities and timelines for implementation of these requirements.

6B. COMMODITY FUMIGATION MITIGATION REQUIREMENTS, PER THE USAID PEA FOR PHOSPHINE FUMIGATION OF STORED AGRICULTURAL COMMODITYUSAID requires that the person/people carrying out commodity fumigation operations hold official certification to perform the fumigation, use fumigants according to the directions on the product label, and follow all listed directions, precautions, and restrictions. Fumigants will be used only for commodities and at sites specified by the product label.

USAID has developed an assessment of environmental and health risks in the fumigation of food assistance commodity entitled USAID Programmatic Environmental Assessment (PEA) for Phosphine Fumigation of Stored Agricultural Commodity. The PEA includes a Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) template, and a Fumigation Management Plan (FMP) template. These tools are intended to assist in compliance with the Fumigation PEA’s requirement for completion of an activity-specific PERSUAP and FMP reporting. The Fumigation PERSUAP should be developed as soon as the warehouse and 42 USAID/Kenya is in the process of developing a new Mission-wide Feed the Future PERSUAP.


fumigation service providers are identified, and in advance of the need for fumigation. It is preferred that this PERSUAP be submitted with the Supplemental IEE, if possible. Specific mitigation requirements for the fumigant phosphine are provided in the Fumigation PEA.

Please note that TOPS has released their Warehouse Staff Safety Guide (November, 2014) which is an excellent resource to assist awardees in the design of education campaigns for warehouse commodity storage. The Warehouse Safety Guide posters, which highlight best fumigation practices, are in compliance with the findings of the Fumigation PEA, and compliments the PEA with practical guidance, information, recommendations and tools to promote warehouse staff safety and prevent injury and illness. The materials include an 80-page manual, 7 Warehouse Staff Safety Posters, a 2-day Facilitator’s Training Tool, and various other tools and checklists to help organizations adhere to minimum safety standards in the warehouse. The Guide was funded by USAID through a TOPS Program Micro-grant and developed by Project Concern International (PCI) and the TOPS Commodity Management Task Force. TOPs has also developed a Facilitator’s Guide to Integrated Pest Management and Fumigation Safety. This includes modules on pesticide compliance, integrated pest management, and phosphine fumigation.

CONDITION 7: SUPPORT THE MISSION IN THE DEVELOPMENT OF ANY BEST PRACTICE REVIEW (BPR) FOR ENVIRONMENTAL SAFEGUARDINGThe Environmental Compliance Best Practice Review (BPR) was developed under the USAID Africa Bureau to enhance environmental management and oversight on USAID programming. Since 2008, over 20 BPRs have been conducted, principally in USAID’s Africa and Asia regions. In 2015, USAID/AFR updated its BPR standard to account for updates to USAID Automated Directives System sections 201 and 204. Building from this updated USAID/AFR BPR standard, there has been a movement by other pillar and regional bureaus to undertake similar reviews, including in DCHA. The purpose of the BPR is to improve the effectiveness of Mission and Bureau compliance with USAID’s environmental and CRM procedures and to better integrate compliance into Mission and Bureau operations. Examples of previous BPRs are available upon request.

Process: DCHA BPR reviews are conducted via a mix of desk review, interviews, and field visits, and result in an action plan to correct gaps and weaknesses in environmental compliance and CRM processes during project design and implementation. BPR reviews are not audits, but voluntary gap analyses. IPs should coordinate with the BPR facilitators to determine the extent to which adequate environmental compliance and CRM procedures are integrated into all processes at the program and activity levels, as well as to identify any areas for improvement.

CONDITION 8: ENSURE COMPLIANCE WITH PARTNER COUNTRY ENVIRONMENTAL REGULATIONSImplementation will in all cases adhere to applicable partner country environmental laws. The Supplemental IEE supports and strengthens the rule of law for systems of


environmental governance in partner countries. In order to ensure environmental compliance, the status and applicability of the partner country’s policies, programs, and procedures in addressing natural resources, environment, food security, and other related issues must be incorporated into each activity. This may include incorporating the national policies pertaining to environmental assessment or other policies related to the sector. Implementing partners must be aware of and ensure compliance to the country’s regulations where their activity is located.

Approved IEEs from the same geographic areas may provide valuable guidance and be a beneficial resource for cross-checking information and developing a deeper knowledge of country-specific regulations and policies. These IEEs are available on the Agency’s Environmental Compliance Database.


6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATIONThe determinations recommended in this document apply only to activities described herein. Other activities that may arise must be documented in either a separate IEE, an IEE amendment, or other type of environmental compliance document.

Other than activities determined to have a Positive Threshold Decision, it is confirmed that the activities described herein do not involve actions normally having a significant effect on the environment, including those described in 22 CFR 216.2(d).

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

● 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).


7.0 REVISIONSPer 22 CFR 216.3(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 AOR to keep the relevant MEO and BEO (Erika Clesceri) informed of any new information or changes in the activity that might require revision of this environmental analysis and environmental determination.


ATTACHMENTS43

ANNEX 1: TEMPLATE FOR SUPPLEMENTAL INITIAL ENVIRONMENTAL EXAMINATIONSANNEX 2: TEMPLATE FOR ENVIRONMENTAL MITIGATION AND MONITORING PLANSANNEX 3: TEMPLATE FOR INSTITUTIONAL ARRANGEMENT PLAN ANNEX 4: TEMPLATE FOR ENVIRONMENTAL STATUS REPORTSANNEX 5: GUIDANCE FOR CLIMATE RISK MANAGEMENT SCREENING ANNEX 6: CLIMATE RISK MANAGEMENT SCREENING TABLE FOR FUMIGATION

43 Word versions of the following templates can be found at the following Google Site: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8



ANNEX 1: TEMPLATE FOR SUPPLEMENTAL INITIAL ENVIRONMENTAL EXAMINATIONS

INITIAL ENVIRONMENTAL EXAMINATIONACTIVITY DATAActivity Name:Amendment (Y/N):Geographic Location(s) (Country/Region):Implementation Start/End:Solicitation/Contract/Award Number:Implementing Partner(s):Link of Other, Related Analyses: Parent IEE: FY 19 RFA IEEORGANIZATIONAL/ADMINISTRATIVE DATAImplementing Operating Unit(s): (e.g. Mission or Bureau or Office)Funding Operating Unit(s): (e.g. Mission or Bureau or Office)Funding Account(s):Funding Amount:Amendment Funding Date: Amendment Funding Amount:Other Affected Unit(s):Lead BEO Bureau:Prepared by:Date Prepared:

ENVIRONMENTAL COMPLIANCE REVIEW DATAAnalysis Type: ☐ Initial Environmental Examination

☐ AmendmentEnvironmental Determination(s): ☐ Categorical Exclusion

☐ Negative Determination☐ Positive Determination☐ Deferral

IEE Expiration Date:Additional Analyses/Reporting Required:Climate Risks Rating for Risks Identified: Low _____ Moderate ____ High

_____


SUMMARY OF FINDINGSPURPOSE AND SCOPE OF THE INITIAL ENVIRONMENTAL EXAMINATION[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a brief statement that this is an Initial Environmental Examination (IEE) for (activity title) operating in the (region) of (country) from (start to end date). If the purpose is to amend a previous IEE to add scope and new activities, briefly state this and what else is changing (funding amount, life of award, geographic scope).]

ACTIVITY SUMMARY[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a brief summary of the activity. Concisely describe how this IEE relates to any other RCEs/IEEs/EAs that cover this activity area for the mission or operating unit.]

ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a summary of the environmental determinations and climate risk ratings applicable to the specific activities.]

Upon approval of this document, the determinations become affirmed, per Agency regulations (22 CFR 216).

IMPLEMENTATIONIn accordance with 22 CFR 216 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 Sections 3, 4, and 5 of the IEE and any BEO Specified Conditions of Approval.


USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATIONACTIVITY NAME:

Approval: __________________________________________________Mission Director

_____________Date

Clearance: __________________________________________________Food for Peace Officer (FFPO)*

______________Date

Clearance: __________________________________________________Mission Environmental Officer (MEO)

______________Date

Clearance: __________________________________________________Agreement Officer’s Representative (AOR)

______________Date

Clearance: __________________________________________________Agreement Officer (AO)

______________Date

Clearance: __________________________________________________Regional Environmental Advisor (REA)*

______________Date

Clearance: __________________________________________________Kyle Rearick, Climate Integration Lead (CIL)

______________Date

Concurrence:

__________________________________________________Erika J. Clesceri, DCHA Bureau Environmental Officer (BEO)

______________Date

*Clearance recommended, but optional.


ACTIVITY DESCRIPTION1.1 PURPOSE AND SCOPE OF IEE[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This section explains the purpose and scope of the IEE. Standard language is provided below to be augmented with activity specifics. If the purpose is to amend a previous IEE to add scope and new activities, briefly state this and what else is changing (funding amount, life of award, geographic scope). Briefly describe how this IEE relates to any other RCEs/IEEs/EAs that cover this activity area for the operating unit.]

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22 CFR 216), 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 22 CFR 216 and specified conditions become mandatory obligations of implementation. This IEE also documents the results of the activity’s 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 are addressed through formal environmental mitigation and monitoring plans (EMMPs) attached and/or Environmental Assessments (EAs), if needed.

1.2 ACTIVITY OVERVIEW[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): In this section provide a brief overview of the activity.]

1.3 ACTIVITY DESCRIPTION[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Describe the activity interventions. This information can be presented in table form, see below. Clearly describe the interventions in detail sufficient to determine whether (1) they belong to classes of actions eligible for Categorical Exclusion and (2) whether direct or indirect impacts are reasonably foreseeable. For guidance in preparing your 22 CFR 216 documentation, please visit http://www.usaidgems.org/Assistant/gettingStarted.htm.]

TABLE 1: DEFINED INTERVENTIONS[Intervention 1 — Title][Intervention 2 — Title][Intervention 3 — Title][Intervention 4 — Title][Intervention 5 — Title][Intervention 6 — Title]


[Intervention 7 — Title][Add rows as needed]


2.0 BASELINE ENVIRONMENTAL INFORMATION[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Include information pertinent to making informed environmental determinations and improving mitigation and monitoring of activities.]

2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL)[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This section is to be tailored and include baseline environmental condition information appropriate to the activity context and scale. The information obtained in this section should serve as an environmental baseline for future environmental monitoring and evaluation and may include information on public health and safety, atmospheric and air quality, water quality, indigenous peoples, etc.]

2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS (E.G. WHO), ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): In this section, summarize partner country environmental, health, and safety laws and regulations, as well as those pertaining to land tenure, relevant to the proposed activities. Discuss applicable permit requirements, policies, and regulations, including whether partner country Environmental Impact Assessment requirements apply.]

2.3 COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS APPROPRIATE)[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): If government-to-government agreements are planned, discuss the state of the entities’ legal enforcement authority, institutional arrangements and capacity building, compliance monitoring, enforcement response, compliance assistance and information management, economic and other incentive-based instruments, indicators to evaluate program success and programmatic priority-setting, public participation, etc. As applicable, also discuss the capacity of local governmental and non-governmental organizations to implement applicable permit requirements, policies, laws and regulations. If there have been consultations with the partner government on the environmental capacity analysis, they should be described here.]


3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL IMPACTS AND CLIMATE RISK [INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): In this section, analyze and document all potential adverse environmental and social impacts of activity interventions, such as water quality impairment, habitat alteration, resource depletion, health, safety, contributions to climate change, increased vulnerability to climate change impacts, etc. With regards to climate change, consider how your activity might contribute to greenhouse gas emissions (e.g., through diesel generators) and how climate impacts may exacerbate the environmental impacts of your activity (e.g., by reducing water flows). How climate risks may impact the success of your activity is considered separately in section 4.2. The information from this section will support analysis sufficient to identify the appropriate mitigation measures and monitoring indicators necessary to avoid or sufficiently reduce impacts of the activity.]

[INTERVENTION 1 TITLE][INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a narrative detailing potential adverse environmental and social impacts for the intervention and summarize results in the table.]

TABLE 2A: POTENTIAL ENVIRONMENTAL IMPACTS AND CLIMATE RISKS – [INTERVENTION 1 TITLE]

[Intervention Title]Potential environmental and social impacts

Potential climate risks

[Description of Intervention]

[Add rows as needed]

[INTERVENTION 2 TITLE][INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a narrative detailing potential adverse environmental and social impacts for the intervention and summarize results in the table.]

TABLE 2B: POTENTIAL ENVIRONMENTAL IMPACTS AND CLIMATE RISKS – [INTERVENTION 2 TITLE]

[Intervention Title]Potential environmental and social impacts

Potential climate risks

[Description of Intervention]



[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Add narratives and summary tables as needed for additional activity interventions.]

4.0 ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a narrative summary of the recommended determinations based on the environmental analysis conducted.]

The following table summarizes the recommended determinations based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22 CFR 216.

[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): For Table 3, add your intervention titles in the table below and place an X in the appropriate column for each title.]

TABLE 3: ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

Interventions

Categorical Exclusion Citation (if applicable)

Negative Determination

Positive Determination Deferral

Climate Risk Rating

[Intervention 1 Title]





4.2 CLIMATE RISK MANAGEMENT[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): In accordance with Agency policy, include a brief narrative of the risk assessment methodology and refer to the the Climate Risk Management Summary Table which should be attached as an


annex(table below or table from Climate Risk Screening and Management Tool). Refer to ADS 201mal “Climate Risk Management for USAID Projects and Activities.”]


5.0 CONDITIONS AND MITIGATION MEASURES[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a narrative here detailing required mitigation measures for reducing the undesirable impacts of the activities on the environment.]

The mitigation measures presented in this section constitute the minimum required based on available information at the time of this IEE and the environmental analysis in Section 4.

[INTERVENTION 1 TITLE]

TABLE 5A: SUMMARY OF MITIGATION MEASURES FOR [INTERVENTION 1 TITLE]

[Intervention Title] Mitigation Measures[Description of Intervention]


[INTERVENTION 2 TITLE]

TABLE 5B: SUMMARY OF MITIGATION MEASURES FOR [INTERVENTION 2 TITLE]

[Intervention Title] Mitigation Measures[Description of Intervention]

[Add rows as needed][INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Add summary tables as needed for additional activity interventions.]


6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATIONThe determinations recommended in this document apply only to interventions described herein. Other activities that may arise must be documented in either a separate IEE, an IEE amendment if the activities are within the same activity, or other type of environmental compliance document and shall be subject to an environmental review.

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

It is confirmed that the activities described herein do not involve any actions listed below. Any of the following actions would require additional environmental analyses and environmental determinations:

[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Remove any bullets below covered by this IEE.]

● 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).


7.0 REVISIONSPer 22 CFR 216.3(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 AOR and awardees 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.

ATTACHMENTS:ENVIRONMENTAL MITIGATION AND MONITORING PLANINSTITUTIONAL ARRANGEMENT PLANCLIMATE RISK MANAGEMENT SUMMARY TABLE BEO ISSUES LETTERREFERENCE DOCUMENTS


ANNEX 2: TEMPLATE FOR ENVIRONMENTAL MITIGATION AND MONITORING PLANS[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Awardees may organize their EMMPs by sector, if appropriate. In any case, all interventions with the potential for environmental effect from the activity’s Logical Framework must be covered in the EMMP.]

Interventions Identified Environmental Aspects or Impacts

Mitigation Measure(s)

Monitoring Indicator(s)

Monitoring and Reporting Frequency/ Methods

Responsible Parties








FY 19 Kenya RFA IEE 52


ANNEX 3: GUIDANCE FOR DEVELOPMENT OF AN INSTITUTIONAL ARRANGEMENT PLAN (IAP)The following guidance note provides information on the process for developing an IAP as is required under Condition 2 of the FFP FY 19 RFA IEE.

PURPOSE The IAP is a useful tool to help frame and describe the budget and staffing needs for IEE implementation. his is not a new requirement, but rather a new framing for an existing need.The IAP describes the, implementing partner capacity for fulfilling the implementation conditions required by the Supplemental IEE, EMMP and CRM screening. This elaboration of responsibilities is necessary to provide for coordination among agencies, partners and stakeholders, and outline the accountability of each party in the entire environmental compliance process.

For the purpose of the IAP, an institution includes the following: lead IP, sub-contractors, research partners, community water users groups, etc. By design, the IAP should not include environmental corrective actions of a technical nature. Rather, the IAP focuses on budget and staffing narratives to ensure successful IEE implementation. This IAP may indeed further elaborate on certain elements in the overall project’s Budget Narrative.

TIMING: IAP submitted Initially with IEE, and then updated with the ESR44.

FORMAT: The IAP should be concise (two to three pages plus the attachment) and should include:

1. Narrative: Description of the institutional and individual responsibilities, per the five following elements:

a. Which actors are responsible for ensuring environmental and climate risk mitigation measures are implemented;

b. Who collects the data, who analyzes it, who prepares reports, who are the reports sent to and how often;

c. How the monitoring data is going to be used for sound environmental performance and climate risk management; and

d. How decisions are taken, responses generated and enforced, and the management process for non-compliance with the EMMP.

2. Table 1 and Figure 1 (see Template below): Table 1 and Figure 1 present the narrative’s information in an organized way to clearly present and conceptualize the responsibilities and relationships between the institutions

44 *The ESR is similar to the Environmental Mitigation and Monitoring Report (EMMR) used elsewhere in USAID. However, the ESR meets both purposes of reporting and budget planning for environmental compliance.


responsible for implementing environmental compliance and CRM requirements.

3. Attachment: IEE Budget and Budget Narrative.

The program implementation arrangements must be chosen based upon careful analysis of programmatic and country contexts. Particular consideration should be taken on ways to keep the IAP as simple and responsive as possible. If program implementation arrangements or responsibilities change during the life of the project, or the need for additional capacity is identified, the IAP must be revised.

---INSTITUTIONAL ARRANGEMENT PLAN FOR PROGRAM XYZ DESCRIPTIONINSTITUTIONAL ARRANGEMENT[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This section describes the roles and responsibilities of individuals at each of the different implementation levels (for example, IP, subgrantees, community, local government, etc.] responsible for implementing environmental compliance and CRM requirements, and the process for coordinating implementation, monitoring, and reporting between institutions.

REQUIRED TABLES AND FIGURESA table is used (see Table 1 below) to clearly outline the roles and responsibilities of those involved in implementing environmental compliance and CRM requirements. A graphic organizational chart is also included (Figure 1) to conceptualize the relationships between the institutions.

TABLE 1 – ROLES AND RESPONSIBILITIES FOR IMPLEMENTING ENVIRONMENTAL MANAGEMENT SYSTEM

Institution Individual Responsibilities / Capacity


[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Insert table that clearly outlines the roles and responsibilities of those involved in implementing environmental compliance and CRM requirements.. An example is shown above.]

FIGURE 1. ORGANIZATIONAL CHART

[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Insert organizational chart of institutions involved in meeting the environmental compliance and CRM requirements and the relationships between them. An example is shown above.]



ATTACHMENT: IEE BUDGET NARRATIVE AND BUDGETIEE BUDGET NARRATIVE[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Attach the IEE Budget Narrative.

The IEE budget is a sub-section of the primary budget of the award. Please cross reference this IEE budget to the primary budget for the entire award. The IEE budget and budget narrative should be a subsection of the primary budget and budget narrative. All changes to the IEE budget MUST be approved in the award itself, not in the IEE.

Per the guidance in the RFA IEE and USAID Environmental Budgeting Toolkit, the narrative includes a description of how the budget (below) is sufficient for fulfilling the conditions required by the Supplemental IEE, EMMP and CRM screening.]

IEE BUDGET[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Attach the IEE budget, which should include provisions for meeting environmental compliance and CRM screening requirements]


ANNEX 4: TEMPLATE FOR ENVIRONMENTAL STATUS REPORTS

ENVIRONMENTAL STATUS REPORT (ESR)ACTIVITY DATAActivity Name:Geographic Location(s) (Country/Region):Implementation Start/End Date:Award Number:Implementing Partner(s):Link of Related IEE:Life of Award (LOA) $:

ORGANIZATIONAL/ADMINISTRATIVE DATADCHA Office:Lead BEO Bureau:Prepared by:Date Prepared:

ENVIRONMENTAL COMPLIANCE REVIEW DATAPREP Year:Environmental Action Recommended:Categorical Exclusion:Positive Determination:Negative Determination:Deferral:


PURPOSE AND SCOPEEnvironmental Status Reports (ESRs45) are required for USAID-funded activities when the 22 CFR 216 documentation governing the activity imposes conditions on at least one of the activity’s interventions. ESRs ensure that the ADS 204 requirements for reporting on environmental compliance are met.

The ESR meets both purposes of reporting and budget planning. ESRs report on status of mitigation and monitoring efforts in accordance with IEE requirements over the preceding activity implementation year. The also ESR describes environmental compliance resource needs over the course of the upcoming year (e.g., staffing, assessments, training, etc).

The ESR is submitted by the Implementing Partner at least three (3) months prior to the annual Pipeline and Resource Estimate Proposal (PREP), The PREP describes an awardee's food security resource needs and activities over the course of the upcoming year.

USAID APPROVAL OF ENVIRONMENTAL STATUS REPORTACTIVITY NAME:

Clearance:

______________________________________Mission Environmental Officer (MEO)

___________________Date

Clearance:

______________________________________Food For Peace Officer (FFPO)*

___________________Date

Clearance:

______________________________________Regional Environmental Officer (REO)*

___________________Date

Clearance:

______________________________________Agreement Officer’s Representative (AOR)

___________________Date

Concurrence:

______________________________________Erika J. Clesceri, DCHA Bureau Environmental Officer (BEO)

___________________Date

DISTRIBUTION: DCHA Climate Integration Lead (CIL); Regional Bureau Environmental Officer (BEO)45 *The ESR is similar to the Environmental Mitigation and Monitoring Report (EMMR) used elsewhere in USAID. However, the ESR meets both purposes of reporting and budget planning for environmental compliance.


*Clearance recommended, but optional.


1.0 INTRODUCTION TO THE ENVIRONMENTAL STATUS REPORT[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Provide a brief synopsis of progress towards achieving environmental compliance and climate risk management objectives as detailed in the RFA IEE, Supplemental IEE and EMMP.

Awardees whose programs are making only limited progress towards achieving environmental compliance and climate risk management objectives should provide an explanation. Describe the extenuating circumstances outside of the control of the award that are impeding progress, and top-line approaches to address these obstacles in the upcoming years.]


2.0 STAFFING AND BUDGET FOR UPCOMING IMPLEMENTATION YEAR[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This section must include responses to Topics 1-4.]

INSTITUTIONAL ARRANGEMENT PLAN UPDATE:

A. STAFFING AND EXPERTISE:[Topic 1: Describe staffing plan for environmental safeguards for the next year. Include responsibilities, level of effort, and authority of staff. A full-time staff with relevant expertise is required for monitoring and reporting on USAID environmental compliance in a timely and professional manner. For guidance, refer to the USAID toolkit describing methods for budgeting.]

[Topic 2: Please describe any environmental assessments (e.g., roads, irrigation), trainings or workshops that will be carried out in the upcoming implementation year (e.g. EA, PERSUAP, FMP, climate risk or vulnerability assessments, community resource mapping exercise, staff training on EMMP monitoring.)]

B. RESOURCES NEEDS FOR ENVIRONMENTAL COMPLIANCE:[Topic 3: Provide a description of the upcoming year’s resource needs for the materials and services for environmental requirements. Illustrative needs are described in Box 2 “Common Materials and Services Needed for Environmental Requirements in FFP Projects” on Page 13 of the USAID toolkit on how to develop and review an environmental compliance budget.]

[Topic 4: Demonstrate that the activity’s budget for environmental compliance is described in the PREP budget and narrative. Where individual budget line items for environmental compliance actions do not exist, then these actions must be described in the budget narrative. This budget indicating resources needs may be reviewed as part of the ESR clearance, and lack of clarity here will cause delays in approval.]


3.0 PROGRESS TOWARDS ENVIRONMENTAL COMPLIANCE[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This section must include responses for Topics 5-11.]

A. PREVIOUS BEO CONDITIONS:[Topic 5: Describe compliance with USAID BEO Conditions from any and all BEO Decision Memos. A specific discussion must be included for each Condition. Discuss challenges or opportunities identified]

B. EMMP REPORTING:[Topic 6: Provide a brief narrative on progress implementing the EMMP. Include description of the EMMP environmental monitoring systems. Include staff or beneficiary trainings conducted, photos of mitigation measures and activities, etc.]

C. INTEGRATION INTO PERFORMANCE M&E SYSTEMS:[Topic 7: Indicate how the awardee has ensured sufficient inclusion of environmental aspects (as in the EMMP) into the M&E Plan, as described in FFP's Policy and Guidance for Monitoring, Evaluation, and Reporting for Development Food Security Activities (Section 2.4 on EMMP, p. 36).]

[Topic 8: Briefly describe any USAID climate risk indicator or other environmental performance indicator. Full details of the results of the indicators are primarily discussed in the Annual Results Reports (ARRs), and need not be described fully.]

D. CLIMATE RISKS AND OTHER ENVIRONMENTAL LIMITING FACTORS:[Topic 9: Provide a description of how the awardee has integrated climate risks and geohazards into activity design and implementation. If applicable, awardees must specifically discuss how Climate Risk Management Screening was completed for all activity elements, per the Climate Risk Management for USAID Projects and Activities A Mandatory Reference for ADS Chapter 201 and guidance found in the RFA IEE. In the description include how findings from Climate Risk Management Screening, particularly all risks classified as ‘moderate’ and ‘high,’ have and will be integrated into activity implementation. Also include a discussion of plans to reduce risk from other environmental limiting factors, such as geohazards, as in 22 CFR 216.1(b)(4).]

E. FUMIGATION PEA:[Topic 10: Provide a description of how awardee is meeting the USAID Programmatic Environmental Assessment (PEA) for Phosphine Fumigation of Stored Agricultural Commodity, by attaching the most recent Fumigation Management Plan (FMP). If no FMP has been completed, provide justification. For activities that are not managing Title II or locally-procured commodity, then disregard.]

F. LESSONS LEARNED AND INNOVATION:


[Topic 11: Discuss any other lessons learned and/or innovation regarding the implementation of systems for climate and environmental resilience and compliance. The awardee is asked to share with USAID any examples to institutionalize environmental safeguards as a cross cutting theme into the awardee’s monitoring systems (e.g. field-based environmental monitoring systems, community-level social and behavioral change tools/strategies, community incentive awards, etc).]

4.0 EMMP MONITORING TABLE[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): This table should align with the most recent version of the activity’s Logical Framework. Please indicate where changes have been made. Any substantial changes to interventions will require an IEE and EMMP Amendment and USAID’s approval. ]

Interventions

EMMP Mitigation Measures

(Indicate any additions or deletions)

EMMP Indicators

(Indicate any additions or deletions)

Results Remarks and Description of Necessary Corrective Actions



5.0 ATTACHMENTS[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): Include relevant attachments, such as water quality test results, Fumigation Management Plans (FMPs), etc.]


ANNEX 5: GUIDANCE FOR CLIMATE RISK MANAGEMENT SCREENINGIntegrating climate risks into project and activity planning helps limit the impacts of climate on implementation. USAID conducts Climate Risks Management (CRM) screening to assess and address climate risks and opportunities in strategies, projects, and activities. This screening is included in the initial environmental examination (IEE), and it will be included in the DCHA Bureau Environmental Officer (BEO) technical review of the IEE. Below is a set of guidance notes and resources to complete the CRM screening.

Requirements: The requirements and basic guidance for completing the climate risk management (CRM) screening at the project and activity level is available in Mandatory Reference for ADS Chapter 201: CRM for USAID Projects and Activities (ADS Guidance). The guidance specific to Activity-Level screening should be followed. This includes development of an Activity-Level Climate Risk Management Summary Table (CRM Table). The table structure showing all columns we require can be seen in Table 1 below.

TABLE 1. CLIMATE RISK MANAGEMENT SUMMARY TABLE

Defined or Anticipated Activity Interventions

Timeframe

Geography

Climate Risks

List key risks related to the activity interventions identified through either the strategy- or project-level climate risk assessment.

Risk Rating

Low/Moderate/ High

Climate Risk Management Options

How are risks addressed

Opportunities to Strengthen Climate Resilience

Describe opportunities to achieve development objectives by integrating climate resilience or mitigation measures.

Table + Narrative: In addition to the CRM Table, the ADS Guidance requires a “summary of the approach to activity-level CRM and major results”. This should briefly clarify how risks were identified and assessed, and also include critical


resources referenced. If there are opportunities to reduce greenhouse gas (GHG) emissions associated with implementing the activity, describe them in the narrative.

CRM Table References: USAID has developed Climate Risk Screening and Management Tools to support this process and provide step-by-step guidance on completing the CRM Table. In particular, please use the Climate Risk Screening and Management Tool for Activity Design (CRM Tool) and the accompanying Matrix Template. While Table 1 (above) shows all columns we require, you may also choose to complete and submit additional columns found in the Matrix Template.

Within the CRM Tool, use the sector-specific annexes, which begin on page 14. In particular, see annexes on “Education, Social Services, and Marginalized Populations”, “Agriculture”, and “Infrastructure, Construction, and Energy”. USAID also developed a technical report entitled “Working with Marginalized Populations: An Annex to the Climate-Resilient Development Framework”. Additional sector-specific environmental design and management information can be found in the USAID Sector Environmental Guidelines, many of which include specific sections covering climate change.

All Activities Screened: Initial screening and risk rating must be conducted and documented for all proposed activities. Section 1 (page 5) of the ADS Guidance outlines the only exceptions, (i.e., emergencies, staffing, research, monitoring). Aside from the excepted activities, all others (including Categorical Exclusion activities) must be screened for climate risks.

All Potential Impacts: The full range of potential climate impacts which might affect the activities must be considered during the climate risk screening. This should be based on reliable available resources and information. The USAID ClimateLinks website provides country and region-specific profiles on climate vulnerability, risk and/or adaptation. The World Bank Climate Change Knowledge Portal also offers country-specific information on historical climate, future climate projections, and climate change impacts and vulnerabilities. Local knowledge and expertise (including from facilities / operations personnel who have experience with local climate risks affecting the school/hospital) should inform the screening, when available and appropriate. The DCHA Climate Integration Lead can also be consulted to provide additional resources, if needed.

TABLE 2. CLIMATE RISK RATINGS


Climate Risk Rating: Based on the screening, all relevant climate risks for each proposed activity must be assigned a rating of Low, Moderate, or High. Table 2 below shows how the severity and probability of negative climate-related impacts interact to determine the climate risk rating. If a climate risk is rated as Low, then only the descriptions of the activity (including timeframe and geography), climate risk, and climate risk rating (columns 1-5) are necessary to include in the CRM Table (Table 1 above). For each climate risk that is rated as Moderate or High, the implementing partner should also describe how the risks will be addressed as well as the opportunities to strengthen climate resilience (columns 6-8 in Table 1).

All interventions related to construction should be categorized as High Risk, and must be assessed and approved by Engineer of Record. The Engineer of Record is an appropriately qualified engineer or firm under contract or subcontract for the purpose of completing the engineering design. If the engineering design has not yet been developed, the DCHA Climate Integration Lead can approve an initial CRM Screening. The Engineer of Record must still ultimately review the initial CRM Screening and revise as necessary. The Engineer of Record must submit the revised, final CRM Screening table and narrative along with a signed document confirming his or her approval.

Example Climate Risk Management Measures: For climate risks rated as Moderate or High, the following illustrative risk management measures are examples of what can be considered when determining and documenting how to address the climate risks (6th column of Table 1).

CLIMATE RISKSCONSTRUCTION MANAGEMENT MEASURES

-Construction workers may face increased risk of heat exhaustion or impacts of climate-related extreme

-Require that construction crews receive proper hydration and are not exposed to dangerously high heat levels, in


events (e.g., heavy rain storms, flooding, dust storms or wildfires)-Extreme climate-related events (e.g., storms, wildfires, extreme heat and flooding), landslides, erosion, as well as sea level rise and associated storm surges can all affect the longevity of buildings and infrastructure. These impacts can be worsened or mitigated based on construction design and siting / location.-The impacts above can also threaten routes and transportation systems necessary to access and utilize constructed buildings.-Extreme climate-related events (e.g., storms, wildfires, extreme heat, droughts, and flooding), landslides, erosion, as well as sea level rise and associated storm surges can all directly affect selected sites in which commodities will be delivered, used and maintained.-Changing rainfall patterns, higher temperatures, or climate-related extreme events may affect transportation routes for delivery or access of commodities

-Changing rainfall patterns or drought conditions could affect availability of

water necessary for use or maintenance of commodities

accordance with local and national health and safety requirements.-Ensure emergency plans are in place (and well communicated to crews) to respond to climate-related extreme events.-Use local knowledge and best practices to integrate design measures to address specific potential climate stressors (e.g., use more resilient materials or construction methods, design for future upgrades/repairs, or elevate to accommodate rising sea levels)-Consider alternative locations if proposed site faces higher climate risks (e.g., floods, wildfires, high winds, storms, or other site-specific threats) than other potential, appropriate locations-Consider locations with multiple access routes, particularly if at least one alternative is protected against relevant climate risks (e.g., paved to protect against wash-out during flooding or routed to avoid low-lying areas possibly affected by storm surges)-Consider alternative locations/buildings/rooms if proposed site faces higher climate risks (e.g., floods, wildfires, high winds, storms, or other site-specific threats) than other potential, appropriate locations-Determine whether additional protective measures can be added to the commodity or structure in which it is housed to increase resilience to climate risks-Develop and/or make use of existing weather/climate information and early warning systems to improve preparedness for and response to climate-related extreme events-Determine or develop back-up/alternative access routes for commodity delivery or for access to and use of commodities


-Determine if alternative water sources are available and develop plans for

accessing them if necessary


ANNEX 6: CLIMATE RISK MANAGEMENT SUMMARY TABLEDefined or Anticipated

Program Interventio

n

Timeframe

Geography

Climate Risks

Risk Rating

Climate Risk Management

Options


Opportunities to Strengthen

Climate Resilience

Commodity Fumigation

Life of the award, until 2023.

Areas where commodity fumigation will occur. Likely country-wide.

Certified applicators unwilling to use personal protective equipment due to increased temperatures.

Low Educate applicators on importance of wearing protective equipment

Educate applicators on importance of wearing protective equipment

Ensure that applicant training includes information on climate risks and emphasizes the importance of protective equipment

Increased temperatures and changes in rainfall patterns, changes occurrence of pests and pathogens and therefore

Medium

Conduct review of relevant literature on how pests and pathogens will change in the area due to climate change and evaluate how that might impact commodity storage and fumigation.

Conduct review of relevant literature on how pests and pathogens will change in the area due to climate change and evaluate how that might impact commodity storage and fumigation.

Ask local

Consult relevant literature and local communities frequently throughout the life of project to understand how pests and pathogens could change due to climate change impacts and how that might impact commodity storage


Defined or Anticipated

Program Interventio

n

Timeframe

Geography

Climate Risks

Risk Rating


Options



Climate Resilience

fumigation requirements.

Ask local community members about observed changes in pathogen and pests over recent years, and use fumigation that is relevant for the current situation.

community members about observed changes in pathogen and pests over recent years and use fumigation that is relevant for the current situation.

and fumigation.

Consider climate change impacts when planning inspection times to ensure that any new pest species or increasing occurrences of pest infestations are identified as early as possible.

Warehouses where commodities are stored are in locations threatened by extreme weather, or in flood zones.

High

During site selection evaluate if storage facilities are in areas that are exposed to extreme weather or regular flooding, or sea level rise in Kenya.

Ensure that all pesticides stored in warehouses (as non-fumigants


Ensure that all pesticides stored in warehouses (as non-fumigants may also be stored in


Improve early warning of climate and weather events, such as rainfall or flood, to


Defined or Anticipated

Program Interventio

n

Timeframe

Geography

Climate Risks

Risk Rating


Options



Climate Resilience

may also be stored in warehouses) are in locations safe from the impacts of extreme weather events (i.e., on raised platforms in the case of flood risk).

warehouses) are in locations safe from the impacts of extreme weather events (i.e., on raised platforms in the case of flood risk).

improve preventative protection of commodities and stored pesticides


Documents

ACTIVITY DATA - ecd.usaid.gov · Web viewLocal farmers in Isiolo use pesticides like Thiodan, Karate, Duduthrin, Bestox, Actellic super, and Sherpa plus to protect their green gram