DCN: RCE for Pakistan Policy and Performance Support ...Based on USAID/Pakistan's emerging Country Development Cooperation Strategy (CDCS) (2018-2023) and technical discussions during

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DCN: &APA- - 19- t'.'.11411. - & &{I RCE for Pakistan Policy and Performance Support Mechanism (3PSM)

USAID PAKISTAN FROM THE AMERICAN PEOPLE

US Agency for International Development (USAID) / Pakistan Request for Categorical Exclusion (RCE)

Pakistan Policy and Performance Support Mechanism (3PSM)

Project/Activity Data:

Activity/Project Title: Pakistan Policy and Performance Support J Solicitation #:N.A. Mechanism (3PSM)

Contract/Award Number (if known):

Geographic Location: Pakistan; 391

Originating Bureau/Office: US AID Pakistan, Office of Program Management

Supplemental IEE: • Yes IZ!No DCN and date of Original document: Amendment: • Yes IZI No DCN and ECD link(s) of Amendment(s): N.A Prograimnatic IEE: • Yes ~No Amendment No.: NA Funding Amount: $90,000,000 Life of Project Amount: $90,000,000

Implementation Start/End: September 2018 - September 2023

Prepared By: Alison Salisbury Date Prepared: March 26, 2018

Expiration Date (if any): Reporting due dates (if any): N.A. Environmental Media and/or Human Health Potentially Impacted (check all that apply): None IZI Air • Water D Land D Biodiversity D Human Health• Other• Recommended Threshold Determination: D Negative Determination D with conditions • Deferral IZI Categorical Exclusion D Positive Determination

Climate Change: IZl GCC/ Adaption • GCC/Mitigation (included)

Adaptation/Mitigation Measures: Included

D Exemption D USG Domestic NEPA action

~ Climate Change Vulnerability Analysis

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DCN: -------------RC E for Pakistan Policy and Performance Support Mechanism (3PSM)



SUMMARY OF FINDINGS:

1.0 Background and Project/Activity Description: 1.1 Purpose and Scope of RCE

The purpose of this Request for Categorical Exclusion (RCE) in accordance with 22 CFR 216 is to provide the first review of the reasonable foreseeable effects on the environment, as well as recommend Threshold Decisions, for the "Pakistan Policy and Performance Mechanism (3PSM) or the "Activity". Activities planned to be implemented under this program are considered to have no negative effect on the natural or physical environment. This RCE is in accordance with 22 CFR 216.2 (c) (1) (i); and 22 CFR 216.2 (c) (2) (i), (iii), (v) and (xiv).

1.2 Background

Based on USAID/Pakistan's emerging Country Development Cooperation Strategy (CDCS) (2018-2023) and technical discussions during the September 2017 Portfolio Reviews, the Mission identified policy refo1m and technical advisory support (i.e., capacity building) as two key areas necessary to support CDCS program implementation.

At the request of Mission leadership, the Office of Program Management (OPM) conducted a survey of the Mission's technical and support offices to understand cunent and planned policy suppo1t and capacity-building effo1ts, and identify any coverage gaps or sh01tfal1s in mechanism flexibility that could hinder effective strategy implementation in the future.

The survey identified policy support and/or capacity-building efforts involving various Government of Pakistan (GoP) offices and other non-government entities as integral components of nume;:uus ongoing activities, all of which will continue (variously) under the new CDCS. However, analysis of the survey data revealed coverage gaps driven largely by the Mission's current approach to policy reform and capacity building. By confmming interventions along narrowly defined and project-specific constructs (in terms of purpose, scope, and partner) cunent practice has resulted in activities that lack the flexibility and broad application necessary to respond quickly to unanticipated requirements. In view of the innate, cross-cutting nature of the CDCS, underscored by its three fully integrated development objectives, such constrained programming practices run counter to the Mission-wide focus needed to serve CDCS implementation demands.

1.3 Requirement for USAID Assistance

On the basis of this analysis on February 9, 2018, the Mission Director approved OPM to move forward with the design of a mission-wide service delivery mechanism called the Pakistan Policy and Perfonnance Support Mechanism (3PSM) that can respond quickly and flexibly to provioe policy and technical capacity-building services to support the Mission's CDCS. 3PSM is envisioned to be a service contract designed to improve selected GoP offices' perfo1mance and to engage the private sector, thereby enhancing the U.S. Government's ability to meet development

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DCN: ___________ _ RCEfor Pakistan Policy and Peiformance Support Mechanism (3PSA1)

commitments made to the GoP. The main objectives of3PSM are to build the capacity of GoP federal, provincial, and local-level institutions as well as other relevant stakeholder organizations; provide advisory services to help structure public-private partnerships; and support collaboration between the GoP and the private sector to develop, implement, and reform policies in order to support implementation of the Mission's CDCS.

3PSM will be a multi-award Indefinite Delivery/Indefinite Quantity (IDIQ) contract that can be utilized by all Mission offices. Mission offices will be able to use 3PSM to respond to requests for policy and capacity-building support and design task orders to respond to specific needs.

3PSM will focus on five main lines of effort:

1.3.1 Policy Development, Implementation, and Reform

Mission offices have identified significant gaps in assistance to the GoP and private sector in formulating and implementing laws, policies, and regulations. Fmther, the private sector also lacks the capability to voice concerns and provide input into policymaking. Assistance to GoP entities, as well as engagement with the private sector on policy development, implementation, and reform, will allow the Mission to supplement existing efforts and further advance policy change and implementation. Moreover, this assistance will strengthen GoP institutions' ability to direct &~id lead implementation of policies effectively and efficiently to further enhance development in Pakistan.

1.3.2 Feasibility Assessments, Needs Analyses, and Applications

Support is required to conduct a variety of studies, including feasibility assessments and needs analyses, cite actions necessary to synthesize assessment findings and information, and assist in the development of next steps to utilize and apply study findings. Work in these areas could include both conducting analyses and assessments and helping GoP entities, as needed, to apply and cany out the recommendations from assessments already conducted by other organizations, including the World Bank, Asian Development Banlc, and UN Agencies. This support may also include assistance with conducting mandatory environmental and social impact assessments, and climate risk needs and analyses as appropriate.

1.3.3 Fublk Administration

Assistance is required to help develop and improve basic public administration functions in the GoP, such as human resources, procurement, Infonnation Technology systems, financial budgeting/management, and strategic planning. USAID already provides some targeted suppo1t in these areas, but mostly in response to managing and mitigating U.S. Government fiduciary risk associated with govemment-to-goverpment assistance programming in compliance with ADS 220. Efforts under this core area would focus on broader institutional support for GoP organizations to enhance and improve public administration functions, including delivering basic services and responding to citizen needs.

1.3.4 Support to Core GoP Ministries

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DCN: ___________ _

RCE for Pakistan Policy and Performance Support Mechanism (3PSM)

The Mission cmTently does not have any activities that provide technical assistance to key GoP pa1tners and provincial/regional offices, including the Finance Ministry's Economic Affairs Division (EAD) (USAID's main GoP counterpart), the Federal Board of Revenue (taxation is:;ues), and the regional planning and development offices. These national organizations serve as the main policy conduits from national to subnational government. They are also responsible for overseeing the design and implementation of development budgets for the provinces. This mechanism could provide suppmt and build professional capabilities within these facilitating entities, which are otherwise unable to access USAID assistance directly.

1.3.5 Professional/Technical Assistance

The Mission lacks the capability to respond to GoP and Pakistani organizations' requests for supplementary professional and technical subject matter experts who can suppott entities in a "smge" capacity. This kind of assistance could support special projects and requirements where inhouse staff is either not available or lacks the right technicai skill set to accomplish specific timebound assignments. Assistance could be delivered through the use of Short-te1m Technical Assistance (STTA) under this award.

1.4 Period of Assignment/Services

The planned implementation period is five years, starting in early 2019, subject to the availability of funds. Over the course of the life of 3PSM, the Mission will be able to design and develop task orders of varying scale, effott, and time aligned under the five lines of effort described under Section 1.3. Each task order will also undergo environmental and climate risk analyses as pa:it of the design process.

1.5 Budget and Deliverables

The funding estimate is $90 million.

2.0 JUSTIFICATION FOR CATEGORICAL EXCLUSION REQUEST The activities described justify Categorical Exclusions, pursuant to 22 CFR §216.2(c)(l) and §216.2(c)(2), for which an Initial Environmental Examination or an Environmental Assessment are not required because the actions do not have an effect on the natural or physical environment.

Specifically, the 3PSM activity, as currently planned, falls into the following classes of action:

a) education, technical assistance, and training [216.2(c)(2)(i)]; b) public awareness campaigns, media campaigns, advocacy campaigns, public information

campaigns, analyses, studies, and workshops [22CFR216.2( c)(2)(iii)]; c) document and information transfer [216.2(c)(2)(v)]; and d) activities that will develop the capability of recipient countries to engage in development

planning [216.2( c )(2)(xiv)]. As currently planned, no interventions will directly affect the environment.

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DCN: ___________ _ RCE for Pakistan Policy and Performance Support Mechanism (3PSM)

3.0 CLIMATE CHANGE INTEGRATION 3.1 Country Climate Change Information (Baseline Information)1

•2•3

Pakistan has 11 climate zones due to its range of topographies and ecosystems, and each of these experiences different weather and climate patterns. Generally, the coastal areas of the country are dry and hot and the northern uplands get progressively cooler. The winter months (DecemberFebruary) are cool and dry. The country experiences monsoons from June through September, with a lesser degree of monsoon activity in October and November.

Temperature: Widespread changes in extreme temperatures have been observed in Pakistan over the last 50 years. Cold or frosty days and nights have become less frequent whereas hot days and nights, and heat waves have become more frequent. According to Pakistan's Task Force on Climate Change, temperature is projected to increase from the 1960-1999 baseline by l.3°C by 2020, 2.5°C by 2050, and 4.4°C by 2080 under one scenario. Under another scenario, temperatures in Pakistan are projected to rise by 1.45°C, 2.75°C, and 3.87°C in 2020, 2050, and 2080, respectively.

Precipitation: Average rainfall in the arid and coastal plains of Pakistan has decreased by between 10 and 15 percent since 1960, while increasing during the same time period over northern Pakistan. Heavy rainfall events have increased, with the nine heaviest rains recorded in 24 hours all being registered in 2010.

Sea Level Rise: The low-lying plains along the coast of Pakistan are exposed to the impacts of sea level rise, with conservative scenarios projecting an increase of 40 cm by 2100.

Extreme Events: Pakistan has experienced about 18 extreme weather events since 1990, including the historic 2010 floods, as well as droughts, cyclones, and landslides. Due to the heavy monsoon rains during the summer months, Pakistan often experiences severe flooding in the Indus River basin where much of the population lives on low-lying lands. Rain or otherwise-triggered landslides are common in the northern regions of Pakistan, particularly those connected to Azad Jamrnu Kashmir province. Lowland plains, especially those sunounding the urban areas of Karachi and Hyderabad, are vulnerable to the impacts of cyclones and stotm surge. Finally, sparse and enatic rainfall patterns can alter water tables, leading to drought conditions in the southern and central regions of Pakistan.

According to USAID/Pakistan FAA 118/ 119, Climate Change, and Ecosystem Services Assessment, and the Global Climate Risk Index (2017), Pakistan is one of the ten countries most affected by climate change and is highly vulnerable to future impacts.

3.2 USAID Climate Risk Management Requirements In the revised ADS 201, dated January 23, 2017, Climate Risk Management is a required analysis for new projects (ADS 201.3.3.13) and activities (201.3.4.5). The Mandatory Reference for ADS Chapter 201, Climate Risk Management for USAID Projects and Activities, dated October 12, 2016, outlines the process and provides tools for so doing.

1 Global Climate Risk Index 2017, available at: https://germanwatch.org/en/download/16411 .pdf 2 USAID/Pakistan FAA I 18/119, Climate Change, and Ecosystem Services Assessment 3 Pakistan Climate Vulnerability Profile available at: https://www.climatelinks.org/resources/pakistan-climatevulnerability-profile

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3.3 Project Activities And Recommended Climate Risk Management Actions: The Agency Climate Risk Screening and Management Tool for use in activity design, updated February 23, 2017, was used to screen 3PSM. The tool is a matrix that systematicaliy identifies the relevant sectors, regions, and timeframes for analysis, and assesses the potential climate change impacts, adaptive capacity, and potential options to address those impacts. The tool includes specific questions related to climate risk that were helpful in identifying specific risks and opportunities.

3PSM will take place in Pakistan. The assessment considered the potential impacts of: climate (temperature, drought, precipitation and flooding, sea level rise and storm surge, and winds and other storms), across the geographical scope, over a 0-15 year time frame.

3PSM is providing technical assistance and policy development, implementation, and reform under task orders. The climate risk for Policy Development, Implementation and Refo1m, Feasibility Assessmmts, Needs Analyses and Applications, and Professional/Technical Assistance effo1ts via USAID assistance (as described in Section 1.3) was dete1mined to be moderate. The improving institutional capacity of government institutions with the technical assistance being provided by the activity influenced the moderate risk rating for the lines of effo1t. The Public Administration and Support to Core GoP Ministries efforts (as described in Section 1.3) was detennined to be low.

Fmther Climate Risk Screening will be applied in the design of individual task orders under 3!>SM. The sector-specific questions in the tool will be heipful in identifying opportunities for those task orders as they are designed.

Due to the moderate risk ratings of three of the levels of effort, 3PSM did require specific climate risk management measures to be incorporated in individual task order design and implementation. The Activity also offers the opportunity to increase awareness and understanding of the impacts of climate change and provides the potential to increase coordination and cooperation to positivc1y respond to and mitigate the effects of climate change by incorporating climate considerations into the policy and capacity-building assistance provided through each line of effort.

In addition to further Climate Risk Screenings, USAID will ensure that all lines of effort incorporate appropriate Climate considerations into task order design, implementation, and monitoring, regardless of Climate Risk Screening Rating. A summary of the conclusions from the analysis is presented in Table 1 below:

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Table 1: Activity-Level Climate Risk Management Summary Table (Each task order will also under5<0 climate risk analy_!is as part of the design

Policy Development, Implementation and

Reform Build the capacity of the GoP and private

sector to develop and implement policy reforms. Increase

engagement between the GoP and private sector to foster the

ability to communicate and provide input into

the policy making process to develop and implement policies that

effectively and efficiently enhance

development in Pakistan.

,.,, ... s:: "' .s .., >, ,.,,

V) ~ -I ~ 0

Climate driven

events (i.e. flooding, drought, sea-level rise, etc.)

may make it difficult or impossible to develop

or implement

policy change.

Lack of capacity, understanding, or

awareness to factor climate change and

events into assessments and analyses. ..,

til ... .., Uncertainty to commit -0

0

to policy development, ~ reform and

implementation due to increased market

volatility from climate variability.

Potential to increase USAID will awareness and

ensure understanding of impacts of Through Recipient's adaptation climate change; USAID's capacity to measures are support address considered Potential to increase

recipient's challenges and taken coordination and into account I ~ capacity will be cooperation to positively

can be built in technical respond to and mitigate the built to through guidance to effects of climate change

respective address USAID by integrating climate challenges. support. organizations considerations into policy

and development, reform and activities. implementation.

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Feasibility Assessments, Needs USAID will

Analyses, and Climate driven ensure Applications events (i.e.

Potential to ensure Through Recipient's adaptation flooding, Lack of capacity,

feasibility assessments, USAID's capacity to measures are Conducting analyses

ell drought, sea- understanding, or needs analyses and support address considered

and assessments; :-. i:: level rise, etc.) awareness to factor B recipient's challenges and taken "" "" "" <l) :-. applications consider and 0 helping GoP entities as >. ell may make it climate change and <l) capacity will be into account z V) J2 "O factor climate change and needed to apply and .... "" difficult or events into 0

can be built in technical I 0... ::;E climate change implications 0 carry out impossible to assessments and

into information that is built to through guidance to recommendations from carry out analyses.

captured. address USAID respective

assessments conducted assessments challenges. support. organizations by other organizations, and analyses. and including World Bank, activities.

ADE, and UN agencies.

Lack of institutional Potential to increase capacity to address

awareness and Climate driven and incorporate understanding of impacts of Public Administration events (i.e. climate vulnerabilities

flooding, into government plans climate change;

Improve basic public ell drought, sea- and processes.

Potential to increase administration ..... i:: level rise, etc.) "" .s <l) s: coordination and functions such as HR, >. ell may make it Impact to government 0 J2 0

cooperation to positively z V) >-l IT, procurement, ...... co difficult or function, delivery of I 0... respond to and mitigate the financial budgeting and 0

impossible to public decentralized management, and carry out services and natural effects of climate change

strategic planning. public resource management by integrating climate

administration. due to predicted considerations into public administration functions climate variability and

and considerations change. .

Support to Core GoP Climate driven Lack of institutional Potential to increase Ministries ell events (i .e. capacity to address awareness and

:-. i:: flooding, and incorporate understanding of impacts of "" .;'.l <l) s: 0 Provide support and >. ,.,, drought, sea- climate vulnerabilities climate change; V) ;_g 0 z build professional ...... "" level rise, etc.) into government plans

>-l 0 ii,

capabilities within GoP may make it and processes. Potential to increase facilitating entities such difficult or coordination and

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DCN: ____________ _ RCE for Pakistan Policy and Performance Support Mechanism (3PSM)

as EAD, Federal Board impossible to Impact to government cooperation to positively of Revenue, and provide function, delivery of respond to and mitigate the

planning and support to public decentralized effects of climate change development offices that ministries. services and natural by integrating climate otherwise are not able resource management considerations into public

to access USAID due to predicted administration functions assistance directly. climate variability and and considerations

chan2:e.

Professional / Lack of institutional Potential to increase

Technical Assistance Climate driven capacity to address awareness and USAID will

events (i.e. and incorporate understanding of impacts of ensure

Supplementary support flooding, climate vulnerabilities climate change;

Through Recipient's adaptation into government plans USAID's capacity to measures are to GoP and Pakistani drought, sea-

and processes. support address considered organization's request "' level rise, etc.) Potential to increase ... ::: E recipient's challenges and taken "' "' "' coordination and for professional and (I.) t; may make it ,_ 0 ;>-. Impact to government (I.) capacity will be into account technical subject matter l/"\ :Q difficult or ~ cooperation to positively z ..... o; function, delivery of 0

can be built in technical experts in a 11surge11 0 0... impossible to ~ respond to and mitigate the capacity to support provide

public decentralized effects of climate change built to through guidance to

services and natural address USAID respective special projects and professional/te resource management by integrating climate

challenges. support. organizations requirements to chnical due to predicted considerations into public

and accomplish specific, support. climate variability and administration functions

activities. time bound assignment. chan!le. and considerations

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DCN: _ ___ ______ _ RCE for Pakistan Policy and Performance Support Mechanism (3PSM)

4.0 REVISIONS

In accordance with 22 CFR 216.3(a)(9) if a project/activity is revised or new information becomes available, which indicates that a proposed action might be "major" and its effects "significant." The Determination will be reviewed and revised by the originator(s) of the projects and activities and submitted through the MEO to the Bureau Environmental Officers, OAP A, for approval. If wan-anted, an environmental assessment (EA) will be launched to prepare scoping statement and EA repo11. The scoping and EA process, if determined necessary during scoping, will follow ;:;nd comply with 22 CFR 216.3(a)(4). It is the responsibility of the COR/AOR/PM to info1m the MEO and BEO-OAP A, in a timely manner, of any changes in the scope and nature of approved activities. These changes may wa1nnt the revision of the approved threshold decisions.

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DCN: ____ _ _____ _ RCEjor Pakistan Policy and Performance Support Mechanism (3PSM)



CLEARANCE/ APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED:

CLEARANCE:

Activity Manager:

Mission Environmental Officer: and Climate Integration Lead

Date: 3 l8-'q l 8c ~ Alison Salisbury

Date:

Regional Environmental Advisor: __,,c=le=ar=-e=d=-e=le""'c:o.:atr,..,.o=m=· c=al..,_ly,.__ __ Date: _...,..M=ar-ch=2_6,~2~0~1-=-8 __ Central, South Asia and OAP A Andrei Barannik

OPMOfficeDirector: cr'Y'~ evinMcGrath

Date:

Qe,"~ \ct'< '-1<t- s(.c... o" a ti l"loti

Deputy Mission Director: Date:

APPROVAL:

Mission Director: 6 l 5J I'- Date: J / '2 'i / t O t b Jerry Bisson

CONCURRENCE:

Bureau Environmental Officer: L ~~ OAPA ~..-------'-,t&hrc....._is~ro~p~h-er~P~a=y=n=e,----

Distribution: 1). Project files, 2). Mission IEE Data base, 3). OAA, 4). RLO

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Asim Aziz <[email protected]>

RCE for 3PSM

Andrei Barannik <[email protected]> Mon, Mar 26, 2018 at 6:42 PM To: Asim Aziz <[email protected]> Cc: Alison Salisbury <[email protected]>, Kevin McGrath <[email protected]>, Pamela Strong <[email protected]>, Nancy Lowenthal <[email protected]>

Dear Asim -

Reviewed - my comments are in the attached - with these incorporated, I clear. When duly approved in the Mission, please send to Chris Payne, BEO/OAPA for his review and clearance.

W/r, Andrei (Quoted text hidden]

Andrei D. Barannik Regional Environmental Adviser for Central and South Asia, and for Off ice of Afghanistan and Pakistan Affairs 1300 Pennsylvania Ave., NW, 5.06-29 Washington, D.C., 20523 Land line: 1.202.712.4161 Cell phone: 1.571 .216.7243

E-mail: [email protected]

USAID Environmental Compliance D atabase: https://ecd.usaid.gov/

i,;:li.i.. Please consider the environment before printing this email

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DCN: RCE for Pakistan Policy and Performance Support ...Based on USAID/Pakistan's emerging Country Development Cooperation Strategy (CDCS) (2018-2023) and technical discussions during