INITIAL ENVIRONMENTAL EXAMINATION (IEE)

PROJECT/ACTIVITY DATA: Activity Name: Safe WaterCountry/region: Philippines/Asia Start Date: 8/15/2019 End Date: 8/15/2024Life of Project Amount ($): $19 million IEE Prepared by: Joanne Dulce and Marian Navata Date: 8/21/2018Amendment: No ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable) Categorical Exclusion: [X] Negative Determination with Conditions: [X] Positive Determination: [ ] Deferral: [ ] CLIMATE RISK RATING : (Place X where applicable)

Low [ ] Moderate [ X ] High [ X ]

Purpose and Scope The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216 (22CFR216), is to provide a preliminary review of the reasonably foreseeable effects on the environment, as well as recommended Threshold Decisions, for the activities detailed below. This document provides a brief statement of the factual basis for Threshold Decisions as to whether an Environmental Assessment or an Environmental Impact Statement is required for the activities managed under the scope of this document. Description of Activities Safe Water is a five-year Activity, with a total estimated cost of $19 million, that seeks to improve the water security of water-stressed communities in Mindanao. By helping to achieve this goal, Safe Water supports the Government of the Philippines’ (GPH) Philippine Development Plan (2017-2022) to build a prosperous, resilient and high-trust society, where no one is poor. It also contributes to USAID’s goal to help the Philippines become a more stable, prosperous and well-governed nation, through improved environmental resilience and access to natural resources and services needed for sustained growth.

The Activity aims to: a) increase access to resilient water supply and sanitation services and b) improve management for sustainable water resources. It will work at the sub-national level, specifically in a select watershed and cities/municipalities in Mindanao, as well as other areas that can potentially advance or complement water security in Mindanao.

1

Under the Statement of Objectives, Safe Water may involve the following activities which are recommended for two threshold decisions:

● Categorical Exclusion pursuant to 22 CFR 216.2 (c) (2) (i), (iii) and (v) - technical assistance and training, capacity building workshops, meetings, technical policy studies and/or research, plans, documentations, evaluations, and public information campaigns; and

● Negative Determination with Conditions - (a) development of new or protection of existing water sources, (b) construction of water and/or sanitation system facilities with power or renewable energy facilities; (c) excavation, installation and/or laying down of water pipes; (d) development of rain water harvesting facilities, cisterns, water tanks, and other water containment structures; (e) forest/watershed restoration and/or conservation/ protection activities.

Background and Objectives of Activity

Water security is fundamental to achieving the Philippines’ economic development, poverty reduction, public health, climate resilience, and human security goals specifically in Mindanao Region. With this, the primary purpose of the Safe Water Activity is to improve water security of water-stressed communities in the said region, characterized by increased access to safe water supply and sanitation services as well as sustainable water resources available to meet human, economic and ecosystem needs.

The Activity will support and aligns with the following USAID strategies, policies and international commitments on sustainable water security:

● USAID/Philippines Country Development Cooperation Strategy 2012 – 2018 Development Objective (DO) 1 Intermediate Result (IR) 1.1 (Economic Competitiveness Enhanced), DO 2 IR 2.1 (Local Governance Strengthened), and DO 3 IR 3.2 (Natural Resources and Environmental Management Approved), sub-IR 3.2.2 (Water supply and security improved);

● Water for the World Act of 2014; U.S. Government’s 2017 Global Water Strategy, USAID’s Water and Development Plan, Climate Change and Development Strategy, Urban Policy, “Sustainable Service Delivery in an Increasingly Urbanized World,” Policy and Program Guidance on Building Resilience to Recurrent Crisis;

● U.S.-Philippines Partnership for Growth with Equity;

● USAID Gender Equality and Female Empowerment Policy, Local Systems Framework and SAID Evaluation Policy; and

● Sustainable Development Goals particularly, a) Goal 6: Clean water and sanitation, b) Goal 11: Sustainable cities and communities, and c) Goal 13: Climate action.

2

Activity Objectives. Improving water security in Mindanao will depend on achieving two interrelated objectives of Safe Water, namely: a) increase access to resilient water supply and sanitation services and b) improve management for sustainable water resources.

It will work at the sub-national level, focusing on cities/municipalities in Mindanao. It will operate in a select watershed (or group of contiguous watersheds) that can strategically demonstrate how watershed, forest and water source interventions, applied with integrated water resource management (IWRM) principles, will lead to improved quality and availability of water resources in cities/municipalities within the watershed boundaries or further downstream. It may also focus on select watersheds and municipalities outside of Mindanao that have the potential to significantly advance water security objectives and/or complement activities in Mindanao. The activity will also work with national and regional government agencies to complement watershed- or local-level interventions and increase their likelihood of success. Subject to USAID approval and depending on levels of security and safety risks, the activity will be mobilized to provide post-conflict or post-disaster support outside of the activity’s geographic sites. The support may include expanding access of communities, IDP settlements as well as select schools and health clinics to new water and/or sanitation facilities or rehabilitating damaged systems.

Country Information Presidential Decree No. 1586, issued on June 11, 1978, established the Philippine Environmental Impact Statement (EIS) System while Presidential Proclamation No. 2146 defined its scope and Administrative Order No. 2003-30 of the Department of Environment and Natural Resources (DENR) provided the implementing rules and regulations.

The EIS System is concerned primarily with assessing the significant impacts of a project on the environment and ensuring that these impacts are addressed by appropriate measures. The EIS System requires all project proponents to prepare an environmental impact assessment (EIA) for any activity that substantially affects the quality of the environment. The EIA should be environmentally conscious, technically sound, and socially acceptable. By being so, the EIS system will not only regulate industrial pollution but also protect natural resources, fragile ecosystems, and the rights of local communities. More than a regulatory scheme, the EIS System is a comprehensive planning and management tool as well. The Environment Management Bureau, a line bureau of the DENR, is the agency responsible for policy development and review as well as monitoring the implementation of EIA-related laws.

The Philippines is also signatory to several international environmental agreements such as the Agenda 21(on Sustainable Development), and Rio Declaration on Environment and Development, United Nations Framework Convention on Climate Change, Hyogo Framework of Action, Convention on Biological Diversity, Convention on International Trade in Endangered Species of Wild Fauna and Flora, and International Tropical Timber Agreement. As a signatory, the Philippines commits itself to the principles of sustainable development, climate change adaptation, disaster risk reduction and management, biodiversity conservation, sustainable forest management, watershed management.

International commitments are supported by national efforts to enact environmental laws and

3

policies. Foremost of these is the Climate Change Act (CCA) of 2009, which promotes the principles of subsidiarity (LGUs to serve as frontline agencies to address climate change at the local level) and multi-stakeholder participation and partnerships. The Disaster Risk Reduction (DRR) and Management Law, passed in 2010, encourages disaster risk prevention and mitigation and establishes the synergies between CCA and DRR. Other relevant laws include: the National Water Code, the Philippine Clean Water Act, Agriculture and Fisheries Modernization Act, the Revised Forestry Code of the Philippines, Executive Order 263 (Community-based Forest Management), and the Expanded National Integrated Protected Areas System of 2017.

Analysis of Potential Environmental Impact While development activities are intended to provide benefits for targeted recipients, when managed ineffectively they may cause adverse impacts that can offset or eliminate these intended benefits. Impacts can be direct, indirect, or cumulative. They can also be beneficial or negative. The USAID Sector Environmental Guidelines are good resources in finding more information on potential impacts for various sectors. The following link is to all sector guidelines: http://www.usaidgems.org/sectorGuidelines.htm. The following are summaries of potential environmental impacts for respective sector(s) that are related to the scope of this IEE, including specifically recommended guidelines. Small Scale Construction

Construction of small scale water and/or sanitation system facilities in areas such as households, schools and health facilities may cause both direct and indirect potentially-adverse environmental impacts. Environmental impacts of special concern include:

• Damage to sensitive or valuable ecosystems• Compaction of the soil and grading of the site • Sedimentation of surface waters• Contamination of ground and water supplies• Adverse social impacts• Spread of Disease• Damage to aesthetics of site/area

Construction of small scale projects also has potential adverse impacts on workers. Worldwide, construction is a dangerous occupation. In developing countries overall, construction is estimated to be on average 10 times more dangerous than in developed economies.

Typical health and safety risks to construction workers in developing countries include falls and falling objects, crush injuries from collapses and heavy equipment, flying debris, and exposure to toxics such as solvents, cement dust, lead and asbestos. Climates with increased temperatures may also lead to more health impacts on workers due to extreme heat stress. Occupational injuries and illnesses can permanently deprive construction workers of the ability to earn a livelihood – and are often fatal.

4

Water supply and sanitation

The following are some potential adverse impacts from mismanaged water and sanitation projects include:

● Morbidity and Mortality - Water supply and sanitation projects may cause increased incidence of infectious water-borne diseases such as cholera, non-infectious disease such as arsenic poisoning, and water-enabled diseases such as malaria, schistosomiasis or bilharzia.

● Degradation to Ecosystems - Adverse impacts to ecosystems can arise from water diversion, construction or decommissioning activities in or near a watercourse, or from fecal contamination of water.

● Depletion of Fresh Water Resources - Depletion of fresh water sources can occur when projects do not adequately assess the quantity of available surface and groundwater (including typical seasonal and annual variations). Other causes include poor mechanisms for regulating withdrawals and use of water, and insufficient monitoring and maintenance of leaks.

● Increased Disease Transmission from Standing and Stagnant Water - Poor design, operation and/or maintenance of water supply improvements can lead to pools of stagnant water near water taps, water pipes and storage tanks. Improper or ineffective practices for disposing of excreta and solid waste can exacerbate this problem. Stagnant water pools form an excellent breeding place for disease vectors (mosquitoes that carry malaria, etc.). They can also increase transmission of water-related diseases, especially when the wet spots are clogged or contaminated with solid waste or excreta.

Forestry

The following are some potential adverse impacts from mismanaged re-forestry and forestry development projects:

● Loss of local biodiversity, including useful niche species● Introduction of exotic or non-native tree species● Conversion of natural forest to tree plantations● Disruption of local communities’ current land uses

Recommended Threshold Decisions ● Justification for Categorical Exclusion Request Some of the activities described justify Categorical Exclusions, pursuant to 22CFR216.2(c)(1) and (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, as currently planned, these activities fall into the following classes of action:

- Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities,

5

etc.)- Analyses, studies, academic or research workshops and meetings- Document and information transfers

The Safe Water activities under review that justify Categorical Exclusion include: technical assistance and training, capacity building workshops, meetings, technical policy studies and/or research, plans, documentations, evaluations, and public information campaigns. ● Negative Determination with Conditions Activities with potential impacts to the environment under the following sectors are recommended for a Negative Determination with Conditions threshold determination. When implemented ineffectively these activities may cause adverse impacts that can offset or eliminate the intended benefits. Mitigating environmental impacts with these activities requires a participatory approach to activity/program design and management. Strong technical design of the projects is also critical. The following are specific conditions to mitigate the potential negative impacts for respective sectors. Small Scale Construction

The following are conditions and best practices that should be implemented:

● All construction activities shall be conducted following principles for environmentally sound construction, as provided in the USAID Sector Environmental Guidelines - Small Scale Construction, which can be found at: http://www.usaidgems.org/Sectors/construction.htm.

● For the rehabilitation of existing facilities and for construction of facilities in which the total surface area disturbed is less than 10,000 square feet, the Implementing Partner shall conduct and prepare a supplemental Environmental Review Checklist (ERC) documenting a site specific environmental review. A link to the ERC template is below. The ERC should include an Environmental Monitoring and Mitigation Plan (EMMP) and answers to the questions from the “Key Questions for Construction Activities” section, starting on page 6 of the above mentioned sector environmental guideline. Construction will not begin until such a review and report is completed and approved by the A/COR in consultation with Mission Environmental Officer.

● For the construction of any facilities in which the total surface area disturbed exceeds 10,000 square feet (1,000 square meters) or are considered to have significant effect on the environment, the IEE must be amended and needs an Environmental Analysis.

● The partner must consider climate resilience in construction planning, including designing plans and activities to minimize the vulnerability of facilities to climate change.

● A USAID Engineer is available to review all construction designs.

A template for the ERC can be found under the Asia section at the following website: http://www.usaidgems.org/compliance.htm. The checklist found at the following website should be used to monitor activities:http://www.usaidgems.org/Documents/VisualFieldGuides/ENCAP_VslFldGuide--

6

Construction_22Dec2011.pdf.

Water supply and sanitation

The following are conditions and best practices that should be implemented for small scale water and sanitation activities (serving less than 5,000 people):

● Follow environmentally sound practices as outlined in the USAID Sector Environmental Guidelines – Water Supply and Sanitation. This document can be found at: http://www.usaidgems.org/Sectors/watsan.htm.

● Calculate yield and extraction rates in relation to other area water uses and available supply in order to determine and ensure sustainable usage.

● Design improvements with an appropriate scale and capacity. ● Assess water quality to determine if water is safe to drink and to establish a baseline so

that any future degradation can be detected. At a minimum, arsenic and/or fecal coliform tests should be conducted.

● Maintain periodic testing. Ongoing testing is the only way to determine if a water supply is or has become contaminated (other than by observing dramatic and sustained increases in water-borne disease).

● Minimize downstream/down-hill effects of intervention, perhaps by assessing potential impacts collaboratively and then establishing regular communication with downstream parties as well as an advertised redress mechanism.

Preventing microbial contamination of groundwater sources from sanitation activities depends on several factors:

● Type of latrine● Water table● Soil type● Distance to nearest water source

Balancing these factors to determine the best combination of siting and sanitation technology should involve input from engineers and/or hydrologists.

The checklist found at the following website can be used: http://www.usaidgems.org/Documents/VisualFieldGuides/ENCAPVslFldGuide--WaterSupply_1Dec09.pdf. and http://www.usaidgems.org/Documents/VisualFieldGuides/ENCAPVslFldGuide--Sanitation_1Dec09.pdf.

ForestryThe following are conditions and best practices that should be implemented:

● All forestry development activities shall be conducted following principles for environmentally sound development, as provided in the USAID Sector Environmental Guidelines – Forestry. This document can be found at the following site: http://usaidgems.org/Sectors/forestry.htm

7

● Implementation of forestry activities should strive to reduce greenhouse gas emissions and maximize sequestration.

● An EMMP shall include the principles of the Forestry guidelines.● Common mitigation measures for different types of forestry activities (e.g. Sustainable

Forestry Management; Agroforestry; Reforestation and Plantation Forestry) can be found on page 31 of the guidelines.

Climate Risk Management

As per the ADS 201mal and the executive order on “Climate-Resilient International Development,” USAID must factor climate resilience into international development programs and investments. Therefore, the design team and/or implementing partner will identify expected climate change impacts over the life of the activity’s expected benefits and demonstrate how those risks will be reduced in order to ensure sustainability of the activity’s objectives.

The Philippines is one of the most vulnerable countries in the world to the negative impacts of climate change due to its high exposure to typhoons, droughts, sea-level rise and intense rainfall. The country is located in the Pacific typhoon belt where it experiences an average of 20 typhoons per year of which 7 to 9 destructive typhoons make landfall. Since 2009, the country has experienced destructive typhoons on almost an annual basis with Super Typhoon Haiyan devastating the central part of the country in 2013. The Philippines’ vulnerability to typhoons is worsened by sea-level rise that affects its vast coastline and by its dependence on climate- sensitive natural resources. Sea-level rise will worsen storm surges and coastal flooding in the coming years, as well as impact the quality of freshwater resources.1

In the Philippines, climate change is already leading to water stress, reducing water quantity, negatively affecting water quality, and damaging water supply infrastructure. Increased temperatures that lead to more frequent and more intense drought reduce water inflows to major watersheds and these in turn lead to water shortages for agricultural, industrial and municipal users who account for 82, 10 and 8 percent of water withdrawals, respectively. Groundwater in the Philippines is over-extracted and its depletion is exacerbated by saltwater intrusion due to sea level rise and by intense rainfall where excessive runoff prevents aquifer recharge. Surface water such as rivers and lakes are vulnerable to siltation that reduces the availability of freshwater supplies. Typhoons, extreme weather events and flooding can also damage water supply and sanitation infrastructure and facilities and disrupt water utility operations and service provision.2

Using the USAID Climate Risk Screening and Management Tool for the Activity, the A/COR, in collaboration with the MEO, came up with a Climate Risk Management (CRM) Summary Table (see Table 1) on assessed risks and how potential climate change impacts will be addressed in the Safe Water Activity.

Table 1: CRM Summary Table

1 Environment Project Appraisal Document, 20172 USAID Factsheet Climate Change Risk Profile: Philippines, August 2016

8

Anticipated Project

Elements

Climate Risks Risk Rating

How Risks are Addressed at Activity Level

Opportunities to Strengthen Climate Resilience

Objective 1: Increase access to resilient water supply and sanitation services

Water Quantity:

Reduced supplies from surface or groundwater sources due to increased temperatures, prolonged drought, excessive rainfall runoff, or sea-level rise

Potential disruption of services or severe water shortages as water resources are affected by warmer temperature or drought

Moderate / High

Help water service providers better prepare and plan for water shortages by building their capacity to integrate climate, weather, and water information in utility planning as well as integrate climate considerations in the design and siting of water supply and sanitation projects

Provide technical assistance (TA) to Water Service Providers (WSPs) in diversifying water sources and complement this with water demand management strategies that include non-revenue water reduction and water efficiency and conservation

Provide TA to WSPs in developing and implementing septage or sewage management programs, which will help protect clean water resources from further contamination

Work with multiple stakeholders to implement IWRM approaches to support equitable allocation of water resources especially in water scarce areas

Collaborate with Philippine Atmospheric, Geophysical and Astronomical Services Administration (PAGASA) and other water resource agencies to utilize available and quality climate, weather and water resource data/ information for application in water supply and sanitation planning

Leverage public and private financing to support the expansion of resilient water supply and sanitation services

Engage with local and international organizations in exchanging and sharing best practices and good models on water security, water conservation and efficiency as well as IWRM

Build the capacity of financing institutions to incorporate climate resilience as a criteria for evaluating and approving water supply and sanitation projects

Water and Sanitation Infrastructure:

Increased damage to water intake and treatment facilities, water distribution systems and/or sanitation facilities as a result of more intense rainfall, stronger typhoons and more frequent flooding

Water pumps and flood control systems damaged, overtopped or potentially rendered useless due to sea-level rise and storm

Moderate/ High

Moderate

Help WSPs better prepare and plan for water shortages by building their capacity to integrate climate, weather, and water information in utility planning as well as integrate climate considerations in the design and siting of water supply and sanitation projects

Build capacity of WSPs to install redundancies in their system

Collaborate with PAGASA and other water resource agencies to utilize available and quality climate, weather and water resource data/ information for application in water supply and sanitation planning

Leverage public and private financing to support the expansion of resilient water supply and sanitation services

Engage with local and international organizations in exchanging and sharing best

9

surges practices and good models on water security, water conservation and efficiency as well as IWRM

Build the capacity of financing institutions to incorporate climate resilience as a criteria for evaluating and approving water supply and sanitation projects

Objective 2: Improve management for sustainable water resources

Water Quality:

Siltation of rivers and lakes due to flooding, erosion and landslides, potentially leading to higher water treatment costs or exceeding the capacity of existing systems

Contamination of clean water sources due to flooding, leading further to increased incidence of water- and vector-borne diseases

Intrusion of saltwater in groundwater resources due to sea level rise

Moderate / High

Moderate

Moderate

Help water service providers better prepare and plan for water shortages by building their capacity to integrate climate, weather, and water information in utility planning as well as integrate climate considerations in the design and siting of water supply and sanitation projects

Provide TA to WSPs in diversifying water sources and complement this with water demand management strategies that include non-revenue water reduction and water efficiency and conservation

Improve the capacity of WSPs to treat and provide quality drinking water

Provide TA to WSPs in developing and implementing septage or sewage management programs, which will help protect clean water resources from further contamination

Collaborate with PAGASA and other water resource agencies to utilize available and quality climate, weather and water resource data/ information for application in water supply and sanitation planning

Engage with local and international organizations in exchanging and sharing best practices and good models on water security, water conservation and efficiency as well as IWRM

Water Demand:

Higher demand for drinking water, increased competition for water or potential conflict among multiple water users (e.g. domestic, agriculture, hydropower) during times of water shortages as a result of drought or increased temperature

Increased incidence of

Moderate / High

Provide TA to WSPs in diversifying water sources and complement this with water demand management strategies that include non-revenue water reduction and water efficiency and conservation

Work with multiple stakeholders to implement IWRM approaches to support equitable allocation of water resources especially in water scarce areas

Engage with local and international organizations in exchanging and sharing best practices and good models on water security, water conservation and efficiency as well as IWRM

Engage with various stakeholders to promote disaster risk reduction, and water efficiency and conservation

10

pilferage and destruction of water pipes as consumers look for more water during times of drought or after a natural disaster

Displacement of vulnerable populations as a result of repeated extreme events

Forests and watersheds:

Increased flooding, land erosion and siltation in watersheds as a result of extreme weather events and typhoons

Increased greenhouse gas (GHG) emissions and changes in agricultural and forest production due to changes in carbon sequestration, decomposition

Moderate / High

Low/ Moderate

Help water service providers better prepare and plan for water shortages by building their capacity to integrate climate, weather, and water information in utility planning as well as integrate climate considerations in the design and siting of water supply and sanitation projects

Provide TA to WSPs in diversifying water sources

Work with multiple stakeholders to implement IWRM approaches to support equitable allocation of water resources especially in water scarce areas

Support communities in adopting alternative sustainable livelihoods

Include carbon sequestration and/or GHG reduction in the watershed management, conservation and/or protection, e.g., forest protection initiatives

Collaborate with the National Government on the implementation of forest conservation and/or rehabilitation programs to protect watersheds

Engage with the private sector in forest conservation

Support national government initiatives to integrate water-energy nexus considerations in national, sector, and local development plans to better use water resources and reduce GHG emissions

Energy

Power outages as operations of hydropower facilities are affected by drought or dryspells

Increased GHG emissions as fossil fuel power plants are utilized to compensate for loss of electricity from hydropower facilities

Moderate /High

Accept and work with multiple stakeholders to implement IWRM approaches to support equitable allocation of water resources especially in water scarce areas

Engage with local and international organizations in exchanging and sharing best practices and good models on water security, water conservation and efficiency as well as IWRM

Collaborate with the National Government on the implementation of forest conservation and/or rehabilitation programs to protect watersheds

11

Engage with the private sector in forest conservation

Support national government initiatives to integrate water-energy nexus considerations in national, sector, and local development plans to better use water resources and reduce GHG emissions

Monitoring and Implementation In addition to the specific conditions enumerated in the Negative with Conditions section, the threshold determinations recommended are contingent on full implementation of the following general monitoring and implementation requirements:

USAID Requirements

1. Environmental compliance actions and results in USAID solicitations and awards. The Contract/Agreement Officer will include language and reference to this IEE in appropriate solicitations and awards. Suggested language for use in solicitation and awards can be found at the following link: http://www.usaid.gov/ads/policy/200/204sac

2. Implementing Partner (IP) Briefings on Environmental Compliance Responsibilities. The Contract/Agreement Officer’s Representative (A/COR) will provide the IP with a copy of this IEE; the IP will be briefed on their environmental compliance responsibilities by their A/COR and MEO/Climate Integration Lead (CIL). During this briefing, the IEE conditions applicable to the IP’s activities will be identified.

3. Compliance Monitoring. As required by ADS 204.3.4, USAID will actively monitor and evaluate, by means of desktop reviews and site visits, whether there are new or unforeseen consequences arising during implementation that were not identified and reviewed in accordance with 22 CFR 216 (Reg. 216). USAID will also monitor the need for additional review. If additional activities not described in this document are added to this program, an amended environmental examination will be prepared in a timely manner and approved.

4. Compliance Reporting. A summary report of Mission’s compliance relative to this IEE will be sent to the BEO on an annual basis, normally in connection with preparation of the Mission’s annual environmental compliance report required under ADS 203.3.8.5 and 204.3.3. The BEO or his/her designated representative may conduct site visits or request additional information for compliance monitoring purposes.

12

Implementing Partner (IP) Requirements

1. Development of Environmental Mitigation and Monitoring Plan (EMMP). For activities that are subject to one or more conditions set out in the “Recommended Threshold Decision” section of this IEE, as well as the “Opportunities to Strengthen Climate Resilience” section of Table 1, the IP will develop and provide an EMMP for USAID A/COR review and approval, documenting how their project will implement and verify all IEE conditions that apply to their activities. The EMMP will also identify how the IP will assure that IEE conditions that apply to activities supported under subcontracts and sub-grants are implemented. (In the case of large sub-grants or subcontracts, the IP may elect to require the sub-grantee/subcontractor to develop their own EMMP). The EMMP shall be seen in the Environmental Screening Report (ESR) or the Environmental Review Checklist (ERC) for infrastructure-related activities.

2. Integration and implementation of EMMP. The IP will integrate the EMMP into their project work plan and budgets, implement the EMMP, and report on its implementation as an element of regular project performance reporting. The IP will ensure that sub-contractors and sub-grantees integrate implementation of IEE conditions, where applicable, into their own project work plans and budgets and report on their implementation as an element of sub-contract or grant performance reporting.

3. Integration of environmental compliance responsibilities in sub-contracts and grant agreements. The IP will ensure that sub-contracts and sub-grant agreements reference and require compliance with relevant elements of the IEE and any attendant conditions.

4. Assurance of sub-grantee and sub-contractor capacity and compliance. The IP will ensure that sub-grantees and subcontractors have the capability to implement the relevant requirements of this IEE. The IP will, as and if appropriate, provide training to sub-grantees and subcontractors in their environmental compliance responsibilities and in environmentally sound design and management (ESDM) of their activities.

5. Compliance to ADS 201mal. The implementing partner is required to comply with ADS 201: A Mandatory Reference for ADS Chapter 201 entitlted “Climate Resilient Management for USAID Projects and Activities” (https://www.usaid.gov/sites/default/files/documents/1868/201mal_042817.pdf) requiring agencies engaged in international development to assess and evaluate climate-related risks and vulnerabilities and to adjust strategies, planning, programs, projects, investments, and overseas facilities, as appropriate, based on the assessments and evaluations.

6. New or modified activities. As part of its initial Work Plan, and all Annual Work Plans thereafter, the IP, in collaboration with their A/COR, shall review all planned and ongoing activities to determine if they are within the scope of this IEE. If any IP activities are planned that would be outside the scope of this IEE, an amendment to this IEE addressing these activities will be prepared for USAID review and approval. No such new activities will be undertaken prior to formal approval of this amendment. Any

13

ongoing activities found to be outside the scope of the approved Reg. 216 environmental documentation will be halted until an amendment to the documentation is submitted and written approval is received from USAID. This includes activities that were previously within the scope of the IEE, but were modified in such a way that they move outside of the scope.

7. Compliance with Host Country Requirements. Nothing in this IEE substitutes for or supersedes IP, sub-grantee and subcontractor responsibility for compliance with all applicable host country laws and regulations for all host countries in which activities will be conducted under the USAID activity. The IP, sub-grantees and subcontractor must comply with each host country’s environmental regulations unless otherwise directed in writing by USAID. However, in case of conflict between host country and USAID regulations, the latter shall govern.

8. Compliance Reporting. IPs will report on environmental compliance requirements as part of their routine project reporting to USAID.

Revisions and Limitations If during implementation, project activities are considered outside of those described in this document, an amendment shall be submitted. Pursuant to 22CFR216.3(a)(9), if new activities are added and/or information becomes available which indicates that activities to be funded by the project might be “major” and the project’s effect “significant,” this determination will be reviewed and revised by the A/COR of the project, and submitted to the MEO and Bureau Environmental Officer for approval and, if appropriate, an environmental assessment will be prepared. It is the responsibility of the A/COR to keep the MEO and the BEO informed of any new information or changes in the activity that might require revision of the IEE.

14

APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

Office Director, Clearance __Cleared____________ _10/3/2018_______ John Edgar Date Mission Environmental OfficerClearance __Cleared____________ _10/4/2018_______ Marian Cruz Navata Date Regional Environmental AdvisorClearance __Cleared w/ edits______ _10/5/2018_______ Mark Childerhose Date

Deputy Mission DirectorClearance ____________________ _________________ Patrick Wesner Date

APPROVAL: Mission Director ________________ _________________Lawrence Hardy II Date

CONCURRENCE: Bureau Environmental Officer ________________ _________________William Gibson Date

15