PROGRAMMATIC INITIAL ENVIRONMENTAL EXAMINATIONSupplemental IEEs (SIEEs), or Environmental Review...

1 MOZAMBIQUE WASH PROJECT PIEE 2019-2024

PROGRAMMATIC INITIAL ENVIRONMENTAL EXAMINATION

PROJECT DATA

Project/Activity Name: Mozambique Water, Sanitation and Hygiene (M-WASH) Project

Geographic Location: Mozambique Amendment: No Implementation Start/End Date 5/1/2019 to 4/30/2024 If Amended, specify New End Date: Solicitation/Contract/Award Number1: AID-OAA-I-14-00059; AID-656-TO-16-00005; 72065618-IO-

00001 Implementing Partner(s): TBD Bureau Tracking ID: Mozambique WASH PIEE 2019-2024

• https://ecd.usaid.gov/document.php?doc_id=52332 Tracking ID of Related RCE/IEE (if any): Moz. Integrated Health Services IEE 2014-2023

● https://ecd.usaid.gov/repository/pdf/50154.pdf Moz. Agriculture, Environment and Business (AEB) Portfolio 2016-2021

● https://ecd.usaid.gov/repository/pdf/49091.pdf WASH Finance global mechanism

● https://ecd.usaid.gov/browse.php

Tracking ID of Other, Related Analyses: UNICEF (PIO) internal environmental procedures

ADMINISTRATIVE DATA

Implementing Operating Unit(s): USAID/Mozambique Other Affected Operating Unit(s): Lead BEO Bureau: Africa Bureau: Brian Hirsch Support Bureau(s): Global Health Bureau: Dennis Durbin, BEO

E3 Bureau: Teresa Bernhard, BEO Funding Account(s) (if available): TBD Original Funding Amount: $55 million If Amended, specify funding amount: If Amended, specify new funding total: Prepared by: Marcia Matenja, Program Development Specialist,

USAID/Mozambique Nathan Sage, Environment Team Leader, USAID/Mozambique

Date Prepared: 4/1/2019. Subm. to BEO 8/22/2019. Rev. 9/27/2019 1 Award numbers for approved activities.

https://ecd.usaid.gov/document.php?doc_id=52332

https://ecd.usaid.gov/document.php?doc_id=52332

https://ecd.usaid.gov/repository/pdf/50154.pd


https://ecd.usaid.gov/repository/pdf/49091.pdf

https://ecd.usaid.gov/repository/pdf/49091.pdf

https://ecd.usaid.gov/browse.php

https://ecd.usaid.gov/browse.php


ENVIRONMENTAL COMPLIANCE REVIEW DATA

Analysis Type: [X] IEE [ ] Deferred (per 22CFR216.3(a)(7)(iv))

Environmental Determination(s): [X] Categorical Exclusion(s) [X] Negative Determination

[ ] Positive Determination

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

9/30/2024

Additional Analyses/Reporting Required: SIEE(s) for site-specific and expanded water and sanitation services WASH activities; WQAPs by IPs, ERRs linked to EMMP

Climate Risks Identified (#): Low ______ Moderate _X____ High ______ Climate Risks Addressed (#): Low ______ Moderate _X_____ High ______

THRESHOLD DETERMINATION AND SUMMARY OF FINDINGS

PURPOSE AND SCOPE

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, as well as recommended Threshold Decisions, for the activities under the Mozambique Water, Sanitation and Hygiene (M-WASH) Project Appraisal Document (PAD). 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. Upon final approval of this IEE, these recommended determinations are affirmed as 22 CFR 216 Threshold Decisions and conditions become mandatory elements of project/program implementation.

This IEE addresses the entire portfolio of activities anticipated under the M-WASH PAD under the USAID/Mozambique Development Objective 4 (DO4) “Health status of target populations improved and Development Objective 2 (DO2) “Resilient, broad-based economic growth accelerated” of the USAID/Mozambique Country Development Cooperation Strategy (CDCS) 2014-2020. The M-WASH PAD, which represents the first USAID/Mozambique project to focus solely on water, sanitation and hygiene sector, will be managed by the Office of Agriculture, Environment and Business (AEB). Several activities with WASH components were carried out under the Mozambique Integrated Health Services IEE 2014-2023 (https://ecd.usaid.gov/repository/pdf/50154.pdf). Supplemental IEEs (SIEEs), or Environmental Review Forms/Environmental Review Reports (ERF/ERR) will be developed with a timeline for completing the Reg 216 requirements for the program as developed under the M-WASH PAD. The Reg 216 process thus completed at the activity level (or just before the award). A Deferral may be needed because insufficient detail and environmental information is available.

ENVIRONMENTAL DETERMINATIONS

The activities under review are recommended for:




● Categorical Exclusion (pursuant to 22 CFR 216.2 (c)(2)(i) and 216 (c)(2)(iii) – Technical assistance, training, workshops and meetings; research, analyses and studies; and projects or programs intended to develop the capability of countries in planning; document and information transfers; and ● Negative Determination with Conditions – Water supply, operations and maintenance, and improvements to achieve both basic and safely managed drinking water; financial transactions that lead to water and wastewater treatment infrastructure development; on-site sanitation and fecal sludge management improvements. Upon approval of this document, the determinations become affirmed, per Agency regulations (22CFR216). The following table summarizes the environmental determinations applicable to the specific activities: TABLE: SUMMARY OF ENVIRONMENTAL DETERMINATIONS

Activities Categorical Exclusion

Negative Determination with Conditions

Positive Determination

Deferral2

Component 1: WASH sector governance strengthened

X

Component 2: Availability of water and sanitation services expanded

X X an ERF/ERR (for subgrants or small activities) or SIEE (for major new programs) must be submitted for approval by USAID.

Component 3: Adoption of key WASH behaviors accelerated

X

BEO SPECIFIED CONDITIONS OF APPROVAL

All new Initial Environmental Examinations (IEEs) for drinking water provisioning activities REQUIRE Implementing Partners (IPs) to develop, implement, and report on a Water Quality Assurance Plan (WQAP). The WQAP must specify how the IP will assure safe drinking water for the project and meet applicable partner-country water quality requirements, given project implementation conditions. The WQAP template, Guidance Note and example documents can be found at

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

http://www.usaidgems.org/wqap.htm



https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/special-compliance-topics/water.

Due to the lack of available detailed information regarding planned actions under Component 2, supplemental IEEs are required for all activities falling entirely or partially under component 2 of this PAD-level Mozambique Water, Sanitation and Hygiene (M-WASH) Programmatic IEE (PIEE). The Design Lead or Agreement/Contracting Officer’s Representative (A/COR) will develop, or direct their partners to develop, and USAID must approve, Supplemental IEEs prior to on-the-ground implementation of any actions covered the SIEE. SIEEs may, however, be prepared after the activity is awarded, during the workplan development period. Supplemental IEEs must include information, analysis and conditions required by any of the applicable GH Programmatic or this M-WASH PIEE.

In many cases, appropriate site-level review may be achieved via the EMMP or appropriate subsidiary review instrument, such as the ERF/ERR, not resulting in a Threshold Decision.

However, where the combination of proposed actions and foreseeable site-specific conditions may, potentially, result in impacts of proposed actions being significant and adverse, the PIEE must require site-level review that results in a site-specific Threshold Decision, based on site-specific baseline information and analysis. In such instances, the PIEE may require one of the following:

1. Site-specific IEEs to supplement the PIEE (supplemental IEEs), 2. Site-specific amendments to a PIEE, or 3. Site-specific EA (i.e., a Positive Determination), when applicable.

Alternatively, site-specific IEEs may be used in lieu of a PIEE. The Mission will likely want to confer with the MEO, REA/REO and/or the BEO on how to parse the appropriate balance.

Specific conditions of this M-WASH PIEE are:

1) Because the application of 22 CFR 216 must be appropriately informed by site-specific conditions and appropriately applied to the specific award/activity, the Design Lead or Agreement/Contracting Officer’s Representative (A/COR) must, upon consultation with the MEO, REA and/or BEO, develop, or direct the IP to develop, Supplemental IEEs (SIEEs) for all activities falling entirely or partially under component 2 of this Mozambique Water, Sanitation and Hygiene (M-WASH) Programmatic IEE (PIEE). These SIEEs must be approved prior to on-the-ground implementation of any actions they cover covered the SIEE.

SIEEs may, however, be prepared after the activity is awarded, during the workplan development period for the IEE to best incorporate specific information regarding sites and actions; however, budgets and workplans must provide for full implementation of the conditions established by the SIEE. These SIEEs must:

a) Provide additional specific details regarding the activity and its entailed actions, including location (environmental baseline), and the impacts associated with all actions.

b) Consolidate all required conditions. For actions addressed by the M-WASH IEE, Supplemental IEEs must, at a minimum, include the conditions for these actions as established by the M-WASH IEE and confirm that no additional activities are planned for the activity at the time of

https://www.usaid.gov/environmental-procedures/environmental-compliance-esdm-program-cycle/special-compliance-topics/water





completion. Additional or more stringent conditions or determinations must be recommended as indicated and documented within the Supplemental IEE.

c) Rectify any deferrals from the M-WASH IEE for the planned award/activity (none herein at time of approval of PIEE).

d) Define and fully comply with 22 CFR 216 requirements for actions that may not have been addressed in the M-WASH IEE because they were defined during the activity design process rather than at the project level. This includes establishing determinations, and as relevant, conditions for these actions.

e) Provide direction for the development of an Environmental Assessment or Scoping Environmental Assessments for actions identified as a Positive Determination.

f) Specifically direct the actions of the implementing partners in the development of necessary subsidiary environmental compliance documentation, including:

i) the Environmental Mitigation and Monitoring Plan (EMMP) for actions assigned a negative determination with conditions in the Supplemental IEE (both new conditions and those reiterated from the M-WASH IEE)

ii) development and implementation of the ERF/ERR for sub-grants and sub-awards. The ERR can become the face sheet for the EMMP.

2) The A/COR will review the Supplemental IEEs against annual work plans to ensure all planned actions remain covered by the IEE and if new actions are identified which fall outside the scope of this IEE, an Amendment will be provided to the BEO for concurrence.

3) If at any time the project is found to be out of compliance with this M-WASH IEE or the associated Supplemental IEEs, the A/COR, MEO, and/or REO shall immediately notify the BEO.

With respect to Mission buy-ins to Central mechanisms (e.g. WASH-FIN), the Mission will coordinate conditions with pertinent E3, Global Health Bureau and other Bureaus’ IEEs as appropriate.

Climate Risk Management has been assessed (see Section 7.1) and approved by the Mission Climate Integration Lead (CIL) and Africa Bureau CIL.

IMPLEMENTATION

In accordance with 22CFR216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Sections 3, 4, and 5 of the IEE and any BEO Specified Conditions of Approval.

9/30/2019


ACRONYMS 22CFR216 Title 22, Code of Federal Regulations, Part 216 ADS Automated Directives System AOR Agreement Officer’s Representative BEO Bureau Environmental Officer CRM Climate Risk Management CLTS Community Led Total Sanitation DfID UK Department for International Development EMMP Environmental Mitigation and Monitoring Plan EMMR environmental mitigation and monitoring reports ERF/ERR Environmental Review Form / Environmental Reporting Form FAA Foreign Assistance Act FSM Fecal sludge management GHG Greenhouse gases IEE Initial Environmental Examination INDC Intended Nationally Determined Contribution MEO Mission Environmental Officer MITADER Ministry of Land, Environment and Rural Development NAPA National Adaptation Programs of Action NEMP National Environmental Management Program PAD Project Appraisal Document PIEE Programmatic IEE PIO Public International Organization PPP Public Private Partnership REA Regional Environmental Advisor UNDP United Nations Development Program UNFCCC United Nations Framework Convention on Climate Change UNICEF United Nations International Children's Emergency Fund USAID United States Agency for International Development WASH Water, sanitation and hygiene WASH-FIN USAID’s WASH Finance Activity WQAP Water Quality Assurance Plan


PROGRAMMATIC INITIAL ENVIRONMENTAL EXAMINATION PROJECT/ACTIVITY NAME: Mozambique Water, Sanitation and Hygiene (M-WASH)

Bureau Tracking ID: Mozambique WASH Programmatic IEE

TABLE OF CONTENTS 1 PURPOSE AND SCOPE OF IEE 9 2 PROJECT DESCRIPTION 9 3 BASELINE ENVIRONMENTAL INFORMATION 11 4 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK 22 5 ENVIRONMENTAL DETERMINATIONS 26

5.1 CLIMATE RISK MANAGEMENT 30 6 CONDITIONS AND MITIGATION MEASURES 36

6.1 CONDITIONS 36 6.2 AGENCY CONDITIONS 38 6.3 MITIGATION MEASURES 39

7 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION 41 8 REVISIONS 41


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

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

2 PROJECT DESCRIPTION The purpose of the M-WASH Project is to increase the use and sustainable management of water and sanitation services, which will contribute to the overall goal of improving the well-being of target communities, especially women and girls.

To achieve this purpose, the Project will focus on three components (also referred to as Intermediate Results or IRs). The first component will strengthen WASH sector governance through participatory dialogue with GRM counterparts coupled with a focus on capacity building to strengthen local systems. The second component will expand availability water and sanitation services by catalyzing domestic private sector resources to complement public sector investments. The final component will accelerate adoption of key WASH behaviors that not only lead to improved health outcomes, but also address sustainability by ensuring that investments in physical infrastructure are used and maintained.


GEOGRAPHIC FOCUS

A 2018 World Bank analysis of WASH and poverty highlights that the poor in Mozambique are mainly concentrated in rural areas—in the provinces of Nampula and Zambézia. Those two provinces represent 38 percent of the country’s total population, with 48 percent of their residents falling below the poverty line. In Zambézia in particular, the poverty gap has been widening over the last 20 years3. Contrary to the urban areas, rural areas have seen their share of the poorest residents grow from 48 percent in 1996 to 55 percent in 2015. The provinces of Niassa, Cabo Delgado, and Nampula have seen even-greater increases in their poor populations, these being estimated at between 67 and 69 percent. These statistics drive a strategic geographic focus toward northern Mozambique. Figure 6 illustrates the geographic concentration of poverty and open defecation rates. Figure. Poverty Headcount and Open Defecation Rates

The M-WASH project will take a multi-faceted approach and use the adaptive management guiding principle to determine the geographic focus over the life of the Project. M-WASH will begin by focusing where the need is highest in Nampula, Zambezia, and Cabo Delgado, which suffer from the highest poverty and malnutrition rates in the country. As noted above, Nampula and Cabo Delgado also have the highest population density. If USAID finds that these areas have reached a saturation point with other donors focusing in the same space, then USAID will adjust and find the next most vulnerable provinces to work in based on the poverty, malnutrition, and open defecation rates. USAID will intentionally layer WASH activities with complementary nutrition and governance focused programming.

USAID will also work where the private sector exists. Currently, the PWPs are primarily based in southern Mozambique. USAID will continue to work with the PWPs and try to expand their investments

3 World Bank. 2017. Findings of the Mozambique Water Supply, Sanitation, and Hygiene Poverty Diagnostic. WASH Poverty Diagnostic. World Bank, Washington, DC.


to the north of the country. USAID will also need to follow the investment opportunities for small town water systems where the political leadership of the small towns is willing to work with the private sector to establish new business models.

In addition, USAID will use existing systems to determine where to work when investing in other platforms such as the PRONASAR Joint Fund. The PRONASAR Joint Fund has an existing system to determine where funds are directed based on a number of factors such as population density, existing funding, etc.

Finally, when crisis strikes USAID will be responsive. Mozambique is extremely vulnerable to climate change that is increasing the intensity of flood and storm events and increasing the frequency of droughts. These events cannot be predicted; however USAID will leave itself the flexibility to move into new areas based on the needs of the people following these types of events. For example, in 2019 Cyclone Idai caused massive destruction in the city of Beira and surrounding areas. The mission will use its resources to complement the recovery efforts following these types of shocks as determined appropriate by the Mission Director.

3 BASELINE ENVIRONMENTAL INFORMATION LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL)

Over the past decade, Mozambique’s economy has expanded at a rapid rate, as evidenced by its gross domestic product (GDP) growing between 5 and 7 percent per year. However, economic growth has not been distributed evenly; almost half of the country’s population still lives in poverty. While poverty exists throughout the country, it is most concentrated in two provinces, Nampula and Zambezia, where 48 percent of the 11.2 million poor Mozambicans live.4

In 2015, 47 percent of the Mozambican population had access to basic water services, 24 percent had access to basic sanitation facilities, and only 12 percent had soap and water available on their residences. In rural areas, these rates drop to 32 percent for access to basic water services, 10 percent for improved sanitation facilities, and 8 percent of households had soap and water on their premises.5,6

The gap in access to basic WASH infrastructure is most acute in the north and center of Mozambique, where poverty and population density is higher than in the south. The national rate (2015) of open defecation in rural areas is 47 percent; however in Zambezia, it is 72 percent7.

Mozambique’s steady economic growth has also been coupled with population growth and rapid urbanization. From 1990 to 2015, the population more than doubled, from 13.6 million to 27.1 million, while the number of people living in urban areas tripled. Urban development has not been able to keep up with the growing population, putting pressure on cities and small towns to provide water and sanitation services. For example, the capital of Cabo Delgado Province, Pemba, is capable of providing water for only six hours per day; and the capital of Niassa Province, Lichinga, is capable of providing

4 World Bank. 2018. Findings of the Mozambique Water Supply, Sanitation, and Hygiene Poverty Diagnostic. WASH Poverty Diagnostic. World Bank, Washington, DC. 5 WHO/UNICEF JMP 2015. https://washdata.org/data. 6 Basic water service is defined as drinking water from an improved source provided that the collection time is not more than 30 minutes for a roundtrip, including queuing. A basic sanitation service is defined as the use of improved facilities that are not shared with other households. 7 WHO/UNICEF JMP 2015. https://washdata.org/data.

https://washdata.org/data





water for eight hours per day. In Maputo, the capital city, water provision in some areas has been cut to less than 5 hours per day.

With support from development partners and non-governmental organizations (NGOs), the Government of the Republic of Mozambique (GRM) has been making substantial investments, particularly in expanding both production and distribution of water supply in both rural and urban areas. In the late 1990s, the GRM embarked on a sector reform process in urban areas, with the implementation of the Delegated Management Framework, which enabled the transfer of operational responsibilities for water supply to professional service providers, and created new sector institutions, including the National Directorate of Water Supply and Sanitation/Direcção Nacional do Abastecimento de Água e Saneamento (DNAAS). In 2010, the National Rural Water Supply and Sanitation Program (PRONASAR) was developed as the main implementation modality for the GRM and has since been jointly implemented by various partners (government, NGOs, international agencies, etc.).

Mozambique’s newly revised Constitution provides opportunities for advancing decentralization of planning, investment and management of government services, including water and sanitation services, to provinces and districts. The GRM and development partners have committed to support the decentralization process, which in the water and sanitation sector is led by DNAAS.

The GRM Five-Year Plan (2015-2019), which lacks a detailed investment plan, includes the following WASH and water resources management goals:

● Increase access to basic water services to 75 percent coverage in rural areas and 90 percent in urban areas;

● Increase access to basic sanitation services to 50 percent coverage in rural areas and 80 percent in urban areas;

● Build and expand the capacity of irrigation and water storage infrastructure; and ● Ensure the integrated management of water resources and international river basins.

Beyond increasing access to WASH, the GRM faces significant challenges in meeting its sustainable development goals (SDGs). These challenges include:

● Weak governance and institutional capacities. The Ministry of Public Works, Housing and Water Resources (MOPHRH), through DNAAS, has overall responsibility for water management. Policies and institutional arrangements exist for the water sector, but implementation remains weak. The evolving and still uncertain legal and regulatory framework weakens transparency and predictability of market signals from government to private investors—individuals and companies—in the water sector, which increases investment and business risks.8 In the sanitation sector, there is a lack of clear policies and strategies and insufficient political will to strengthen weak service delivery institutions.

● Sector financing gaps, particularly for rural sanitation. The GRM estimates that approximately $4.16 billion in WASH sector financing (75 percent water and 25 percent sanitation is needed to achieve universal access by 20309. The GRM plans to invest $80 million in water and water resource management in 2019 to meet the targets set in the GRM Five-Year Plan 2015-2019. At these rates, the annual investment needs for the sector will reach less than a quarter of the

8 USAID. 2018. Rapid Water and Sanitation Market Assessment. USAID/Mozambique SPEED+ Activity. https://pdf.usaid.gov/pdf_docs/PA00TMHV.pdf. 9 Club of Mozambique. “Four billion dollars needed for water and sanitation – Government.” 10 Feb 2017. https://clubofmozambique.com/news/four-billion-dollars-needed-water-sanitation-government/

https://pdf.usaid.gov/pdf_docs/PA00TMHV.pdf


https://clubofmozambique.com/news/four-billion-dollars-needed-water-sanitation-government/

https://clubofmozambique.com/news/four-billion-dollars-needed-water-sanitation-government/


goal. About 75 percent of these funds are allocated to urban areas while 25 percent to rural areas. In the last seven years, on average about 80 percent of the funding for the WASH sector came from external resources.

● Low sustainability of WASH service delivery. Approximately 30 percent of water points are non-functional at any time. Communities are left to maintain water points after they are constructed because District Water Offices do not conduct routine monitoring and maintenance. The challenge to maintain water points increases in remote areas with low population density.

● Poor nutritional status compounded by weak health infrastructure. Currently, there are only 1,300 health facilities in the country, many of which are in a poor state of repair and lack essential services such as water, functioning sanitation and waste disposal systems, and electricity. Malnutrition and stunting rates are increased due to deficiencies in basic water and sanitation services. Chronic malnutrition (stunting or low height-for-age) affects more than two million children under the age of five (43 percent)10.

APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS (E.G. WHO), ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS

The Constitution of the Republic of Mozambique approved by the Parliament in 2004 states that all citizens have the right of living in a balanced environment and the obligation of protecting it from degradation. The Constitution also states that natural resources located underground, in the soil, sea, and freshwater belong to the State, and the Constitution calls for the need to establish areas for the protection of nature. Accordingly, the State should adopt policies to protect the environment and encourage sustainable use of natural resources. It is in this regard that Mozambique has approved policies, laws and regulations to protect the environment for future generations. Based on the National Environmental Management Plan, the Environmental Law (July 30, 1997) defines the legal basis for the proper use and management of the environment and its components in order to establish a system of sustainable development in Mozambique. Article 13 of the Environment Law provides a legal basis for the creation of protected areas, prohibiting pollution and mandating environmental quality standards. Article 30 of the Environment Law recognizes the need to guarantee the participation of local communities and to utilize indigenous and local knowledge in environmental management. The Environmental Framework Act (Act 20 of 1997) provides for the participation of local communities, among others, in the development of policy and laws for the management of natural resources, management of protected areas, and policing environmental norms. It also establishes conditions for environmental impact assessment in order to avoid environmental disasters. Its 34 articles define natural elements, as well as authorized activities relevant to the exploitation of the environment and also establish national programs for environmental management under the responsibility of competent authorities. Some of the Decrees related to the environment in Mozambique include:

10 USAID 2018. Mozambique Nutrition Profile. March 2018. https://www.usaid.gov/sites/default/files/documents/1864/Mozambique-Nutrition-Profile-Mar2018-508.pdf.


Decree No. 8/03 on the Regulation of Bio-Medical Waste Management, which approves the Regulation on Bio-Medical Waste Management. This Regulation applies to any waste produced by bio-medical activities and aims at granting health and safety of workers, minimizing, at the same time, the environmental impact. To this end, it provides waste management specific plans and provides a detailed classification of waste typologies. Special attention is devoted to hazardous and radioactive substances;

Decree No. 6/2009 on approving the Regulation on Pesticides Management approves the Regulation on Pesticides Management and aims at guaranteeing the human health and the environmental quality standards, according to environmental legal proceedings approved by Law No. 20/97, defining institutional competencies and establishing on registration, authorization, managing, composition, classification, and inspections to be carried out on pesticides;

Environmental Audit and Environmental Inspection are regulated by Decrees No. 32/2003 of August 20, 2003 and No. 11/2006 of July 15, 2006 respectively. The Regulation on Environmental Audit stipulates that public or private activities are subject to public environmental audits conducted by MITADER or by private entities. As per this regulation, audited entities are required to provide to the auditors a full access to the sites to be audited as well as information that may be required as part of the process. The regulation on Environmental Inspections regulates the mechanism for inspection of public and private activities, which directly or indirectly have the potential to cause negative environmental and social effects. This Law aims at ensuring that development activities are in compliance with procedures established for environmental protection.

The Ministry Diploma No. 130/2006 of July 19 makes provision for the public participation process related top Environmental Impact Assessment, defining the basic principles for Public Participation methodologies and procedures that should be used. Emphasis is placed on the need to consult with affected or interested stakeholders who may be directly or indirectly affected by a development project.

Regulations on Environmental Quality Standards for Effluent Emission—Decree no 18/2004 of 2nd of June. This regulation aims at establishing environmental quality standards for effluent emissions with a view to ensure effective control and supervision on the environmental quality and the natural resources. Article 16 of this Decree specifies the requirements for discharge of pollutants or liquid effluent into the environment. Paragraph 2 of this article indicates that the location of any effluent emission or discharge source shall be determined during the undertaking of environmental impact assessment process, with a view to ensure that such discharge does not result in change in the water quality of the receiving environment, which would limit the use of such water for other means. Paragraph 3 emphasizes that discharge of domestic effluent to an aquatic environment shall take into consideration the standards set on this Decree.

Regulations for Environmental Impact Assessment—passed in 1998 and revised through Decree no. 45/2004, dated September 29, 2004—were recently revised again through Decree no. 54/2015, dated December 15, 2015. These Regulations specify that all programs and projects that may directly or indirectly affect sensitive areas shall be subject to Environmental Impact Assessment (EIA).


Environmentally sensitive areas include conservation or protected zones or areas, zones where habitats and ecosystems are in danger of extinction, and natural forests.

The Land Policy (Resolution No. 10/95)- The national land Policy approved by Council of Ministers, establishes that the State should provide land for every family to have or build their own houses and that the State is responsible for land-use planning, although plans may be prepared by private sector. The objective of this policy was to entrench the rights of the population over the land and other natural resources while promoting investment and sustainable and equitable use of these resources. Water Policy (Official Gazette No. 43/Series I, supplement 5 of October 30, 2007) – In August 2007 the Cabinet Council approved the new national Water Policy. This new policy is a review of the water policy of 1995 (of Boletim da Republica, I Serie No. 34 of August 23), which emerged from the Water Law of 1991. The new Water Policy intends to achieve the following objectives: i) Satisfaction of basic needs; ii) Improvement of sanitation in urban and rural areas; iii) Water efficiency for economic development; iv) Reduced vulnerability to flooding and drought; v) Water for environmental conservation; vi) Agreements on water allocations and management coordination for international river basins.

COUNTRY/MINISTRY/MUNICIPALITY ENVIRONMENTAL CAPACITY ANALYSIS (AS APPROPRIATE)

Government - Policy and Regulatory Bodies

The GRM has various government institutions responsible for the policy, regulation, and provision of water and sanitation services in rural, urban, small-town, and peri-urban areas. See USAID Rapid Market Assessment11 for further details.

• DNAAS, within MOPHRH, is responsible for policy development, management, strategies and investment mobilization for water supply and sanitation in rural and urban areas. DNAAS leads the implementation the National Program for Water and Sanitation in Rural Areas (PRONASAR). With USAID support, DNAAS led the development of Decree 51/2015 that legitimized the role of PWPs under five-year licenses.

• Water Regulatory Council/Conselho de Regulação do Abastecimento de Água (CRA): CRA was created as an autonomous entity to reconcile the interests of users and their public and private water supply providers. CRA also works to ensure a balance between the quality of service, the interests of users, and economic sustainability (including adjustment of tariffs). CRA sets the tariffs for both public and privately operating water systems and regulates sanitation treatment and disposal. All water tariffs must be approved by the relevant municipal council. The involvement of municipal councils in tariff approvals potentially introduces political influence onto CRA’s ability to function as an independent regulator and set tariffs that enable water system operators to recoup operating costs and depreciation while protecting customers from exorbitant charges. CRA also has a regulatory enforcement mandate, but lacks the resources to conduct and process water testing kits.

• Regional Waters Administration (ARA) is tasked with regulating the use of surface and ground water resources by authorizing and registering well development and collecting fees for water abstracted by both public and private water service providers. ARA has five regional offices (South, Central, Center-North, Zambezi, and North).

11 USAID. 2018. Rapid Water and Sanitation Market Assessment. USAID/Mozambique SPEED+ Activity. https://pdf.usaid.gov/pdf_docs/PA00TMHV.pdf.




• Municipal/District Governments play an increasingly more important role in rural water and sanitation sector as PRONASAR incorporates more decentralized planning and investment systems and international partners strengthen the capacity of local institutions to implement and monitor these investments. Within the context of privatized water provision as promulgated in Decree 51/2015, a Water and Sanitation Representative under local authorities, municipal councils and district governments are charged with the provision of licenses to all PWPs—although many municipalities collect an annual business fee from PWPs in lieu of managing a formal licensing system.

• Ministry of Health/Ministério da Saúde (MISAU): Hygiene and sanitation activities are included in MISAU’s responsibilities. The ministry also responds to the health effects of emergencies such as floods. At the sub-national level, a Provincial Health Directorate organizes and coordinates health and WASH activities for each province, and leads the various District Services for Health, Women and Social Action.

Government - Water Service Providers

• National Directorate of Water and Resources Management/Direcção Nacional de Gestão Recursos Hídricos (DNGRH), within MOPHRH, is responsible for developing policies and strategies related to the conservation, use, and exploitation of water resources and river basins, including state management for drought and flood planning and mitigation.

• Water Supply Investment Assets Fund/Fundo de Investimento e Património do Abastecimento de Água (FIPAG) manages public investment and maintenance of the urban water supply networks in 21 cities across Mozambique through 15 regional offices12. FIPAG directly manages 15 city water systems and has delegated the management of another six urban water systems to a private operator. FIPAG also manages one small town system in Ilha de Moçambique.

• Water and Sanitation Infrastructure Administration/Administração de Infra-Estruturas de Água e Saneamento (AIAS): AIAS was established as an autonomous public entity to manage water supply and sanitation systems in 130 small cities and towns outside of FIPAG’s scope. AIAS has constructed water systems in five secondary cities and 126 towns13.

ACTIVITY PLAN

Ongoing Activities. The table below describes current, ongoing activities aligned with the M-WASH Project. Details include activity name, link to project IRs, instrument type, planned period of performance, and total estimated cost.

Activities Name Link to Project

IRs Instrument Type

Period of Performance and Total Estimated Cost

1. Strengthening Policy Environment for Economic Development (SPEED+)

1.1; 1.3; 2.2

Contract Task Order

2016-2020; $3M

2. Water for Africa through Leadership and Institutional Support (WALIS)

1.2 Contract Task Order

2018-2019; $400k

12 USAID. 2018. Rapid Water and Sanitation Market Assessment. USAID/Mozambique SPEED+ Activity. https://pdf.usaid.gov/pdf_docs/PA00TMHV.pdf. 13 USAID. 2018. Rapid Water and Sanitation Market Assessment. USAID/Mozambique SPEED+ Activity. https://pdf.usaid.gov/pdf_docs/PA00TMHV.pdf.






3. WASH Finance (WASH-FIN) 1.1; 1.2; 1.3; 2.1; 2.2; 2.3

Contract Task Order

2018-2021; $4.8M

4. WASH in Health Centers 1.2; 2.1; 2.1; 2.3

PIO Grant 2018-2022; $6M

Planned and Tentative Activities of the M-WASH Project

Planned & Tentative Activities Name Link to Project

IRs

Instrument Type

Period of Performance and Total Estimated Cost

5. Breakthrough Research on Social Behavioral Change (Planned)

3.1; 3.2; Contract Task Order

2019-2021; $1M

6. Transform Nutrition in Nampula (Planned) 3,1; 3.2; 3.3

Local System 2019-2023; $4M

7. Water, Sanitation, Hygiene & Women's Empowerment (Planned)

2.3; 3.1; 3.2; 3.3

Local System 2019-2023; $18M

8. PRONASAR Joint Fund for Rural Water Supply & Sanitation (Planned)

1.1; 1.2; 2.1; 2.2; 3.3

Delegated Cooperation Agreement with DfID

2020-2024; $20M (equivalent to $5M/year; it is possible to continue support for PRONASAR through 2030)

9. Local Governance & Decentralization (Planned) 1.1, 1.2, 1.3

TBD 2020-2024; $3M

10. Small Towns Water Fund (Tentative) 1.1; 1.2; 2.1; 2.2; 2.3; 3.3

TBD 2020-2024; $4.6M

11. Strengthening Private Water Providers (Tentative) 1.2; 1.3; 2.2; 2.3

Contract 2021-2023; $3M

12. Parceiros in Cabo Delgado GDA (Tentative) TBD TBD 2021-2023; $1.5M

Details of Existing and New Activities of the M-WASH Project

Activity Name Total Estimated Cost

Activity Description

The following activities are ongoing and have been approved. WASH components will fall under the M-WASH PAD.

SPEED+

$3 million Demand-driven policy reform activity. WASH component aims to increase private sector investment in the water sector to serve more customers with high quality service by supporting implementation of national system regulating private water providers; nationwide mapping and creation of national database of these providers; support to CRA to establish a tariff structure. Support to DNAAS and AFORAMO (association of private water providers) to catalyze provision of piped water in peri-urban and small town areas.

WALIS $400,000 Africa Bureau technical support to National Water Sector Information System (SINAS) including demonstration pilot of web-based decision-support platform in Cabo Delgado, Manica, Maputo and Sofala provinces. Data from other provinces supported by other donors will be integrated into SINAS. Program includes data collection training,


enterprise development of software, and the provision of tablets, computers and a server.

Water, Sanitation and Hygiene Financing (WASH-FIN)

$4,782,104 Technical assistance aimed to deliver sustainable and creditworthy business models, increased public funding, and expanded market finance for infrastructure investment. WASH-FIN in Mozambique will expand financing for viable water and sanitation service providers to enable them to invest in improving their service quality and/or increase client access to safe water and adequate sanitation through: (1) increase understanding of WASH financing options; (2) transaction support services to private water and sanitation providers; and (3) support for alternative financing opportunities (e.g., UNICEF Small Towns Fund with AIAS).

WASH in Health Facilities

$6 million Focus on health facility water and sanitation infrastructure improvements in Nampula, Sofala and Zambezia provinces. Complementary site-level activities in medical waste, laundry, and hygienic kitchens, as well as central-level policy advocacy for increased planning & investment in WASH at all health facilities. Target: Improved institutional WASH in 70 health facilities and 6 pilot schemes linking O&M to local communities.

Transform Nutrition

$4 million Transform Nutrition aims to improve the nutritional status of pregnant and lactating women, adolescent girls, and children less than 2 years of age in Nampula province. Intermediate Results include: (1) strengthened host government capacity to plan and manage nutrition programming; (2) increased adoption of optimal behaviors to improve the nutritional status of target populations; and (3) increased access to quality services and products for nutrition, sanitation, and hygiene. WASH funds (for IR3) will target improved open-defecation free (ODF) and soap usage rates of 1.83 million people (30 percent of 6.1 million total population of Nampula).

Activities being authorized for design and procurement under the M-WASH Project Appraisal Document

Breakthrough RESEARCH

Up to $1 million

Global SBC mechanism capable of generating evidence through social-science research and evaluation with focus on gender equality and youth empowerment. The activity would enable crucial cutting-edge research into innovative SBC interventions and identify the and most efficacious entry points for changing gender norms within WASH and Nutrition interventions, which can potentially be implemented and scaled via local partners.

Water, Sanitation, Hygiene & Women's Empowerment

$18 million This activity, which has potential for co-creation/co-design, will focus on social behavior change (SBC) related to water, hygiene, and sanitation, increased engagement of women in WASH decision making, and access to improved sanitation, in the geographic focus area of northern Mozambique (Nampula, Zambezia, Cabo Delgado). SBC activities will create demand for sanitation products and services, utilizing research and findings from Breakthrough RESEARCH. A component will strengthen the sanitation market and engagement of the private sector. Activities will include a sanitation marketing and supply chain assessment, and development of cost-effective, gender-sensitive, affordable sanitation solutions, and implementation of Community Led Total Sanitation (CLTS) approaches beyond the area covered by Transform Nutrition. In addition to the sanitation focus, activities with community-level water and sanitation management groups will increase women’s participation in WASH-related decision making. Innovative models for community water management that addresses payments, rehabilitation and sustainability of systems may also be addressed


PRONASAR Joint Fund for Rural Water Supply & Sanitation

$20 million (2020-2024)

The National Rural Water Supply and Sanitation Program (PRONASAR) represents a joint effort between GRM, development partners, and NGOs in Rural Water Supply and Sanitation at central, provincial, district and local levels. PRONASAR's Annual Implementation Plans comprises investments from State Budget, development partners through the Joint Fund, and partner organizations that fund AASR activities outside the Joint Fund. PRONASAR Joint Fund is being developed jointly by DNAAS, DfID, Austria, Switzerland and UNICEF. On-CUT financial allocations will be managed by DNAAS/DAF, DPOPHRH/DAF, and district financial structures. Off-CUT financial allocations will be managed by an external fund manager. UK/DfID will support the development of Off-CUT financial management mechanisms, provincial/district-level technical assistance (implemented by SNV) to develop results-based indicators, and independent verification of annual provincial progress reports using these indicators. USAID and DfID will enter into a Delegated Cooperation Agreement that will facilitate Off-CUT support to PRONASAR Joint Fund (and associated costs) and technical assistance (SNV or other).

The following activities are illustrative, and will require PAD Amendment Memos for formal authorization prior to proceeding with full activity design.

Local Governance & Decentralization

$3 million WASH funds may be used to support the Mission’s new, cross-cutting Local Governance and Decentralization activity currently in design. Provincial or municipal-level activities would align with Sub-IR1.2: Institutional capacity to plan, budget, implement and monitor improved and Sub-IR1.3: Business climate to attract private sector participation strengthened. As this activity is in the initial design stages, further discussion will be needed on the extent to which the activity will be supported with WASH funding.

Small Towns Water Fund

$4.6 million Under WASH-FIN Activity, technical assistance is provided to analyze a concept note, developed by UNICEF, to establish an investment fund for water supply and sanitation in small towns, based on the existing public-private partnership model used by the GRM to engage with the private sectors. The World Bank has expressed interest in being the fund manager, working in partnership with AIAS. In that scenario, USAID could fund either a bilateral grant to a trust fund or a risk guarantee (e.g., Development Credit Authority).

Strengthening Private Water & Sanitation Providers

$3 million Increase sustainable access to drinking water and/or improved sanitation in rural areas and small towns by: (1) strengthening institutions to deliver WASH services (planning, budgeting, monitoring); (2) increasing the availability of functional water and sanitation infrastructure in select districts; (3) testing and/or scaling up innovative financing and business models to increase sustainability. To the extent feasible, the activity will aim to share best practices from USAID’s engagement with PWPs in the greater Maputo area with investment opportunities in Cabo Delgado, Nampula, and Zambezia provinces. Strengthening associations of PWPs to scale investments and share risk in untapped and relatively more distant markets will also be explored. Technical training to both public and private water engineers and technicians, particularly those in select districts of northern Mozambique. Activities may also cover Maputo Province.

Parceiros in Cabo Delgado (GDA)

$1.5 million Funds are set aside for activities in Cabo Delgado, perhaps to be implemented through a public private partnership with one or more private sector companies active in Cabo Delgado, a proposed focus area of USAID CDCS under design. Funds could also be used for a multi-sector program focused on improving local governance, including through support to community-level efforts to improve access to water and sanitation.

USAID PARTNERSHIP WITH OTHER ORGANIZATIONS

USAID will work closely with other development partners, including UNICEF, to support the GRM to improve policies, strategies and institutional frameworks as well as advocate for and provide needed technical assistance to promote increased public investment, planning and management in the water supply and sanitation sectors, particularly for underserved areas. Aligning objectives and incentives among different actors is important in achieving WASH sector outcomes. USAID support through


UNICEF, a public international organization (PIO), is subject to environmental review under 22 CFR 216. For the proposed WASH activities, the mission has undertaken a review of UNICEF’s Environmental procedures and conclude that this PIO has capacity to integrate environmental considerations into the WASH activities using UNICEF’s internal procedures to similar standards as that of 22 CFR 216.

UNICEF ENVIRONMENT AND CLIMATE FRAMEWORK

UNICEF has developed a Strategic Framework on Environmental Sustainability for Children for which also includes climate change considerations. The purpose of the framework is to strengthen the environmental and climate sustainability of UNICEF’s programs in advocacy, research, and engagement through five priorities:

1. Strengthen policy and guidance on environmental sustainability as a cross-cutting theme; 2. Strengthen the inclusion of environmental sustainability in UNICEF programs; 3. Advocate for full recognition and inclusion of children in the policy discourse on environmental

sustainability; 4. Strengthen opportunities for children’s development and well-being to benefit from

environmental sustainability related public and private finance; 5. Incorporating environmental sustainability management in the organization.

The UNICEF Framework has been designed to be consistent with the “Framework for Advancing Environmental and Social Sustainability in the United Nations System” developed by the UN Environment Management Group (UN EMG) in 2012, and which promotes and guides harmonized approaches to environmental and social sustainability across UN agencies. The EMG Framework provides a basic architecture for integrating environmental and social sustainability (ESS) measures into the three “entry points” of policies/strategies, programmes/projects, and operations/facilities. UNICEF’s Division of Data Research and Policy coordinates the implementation of the framework with field offices and National Committees through existing planning, decision making, reporting, and coordination structures when possible. Progress is monitored through annual reporting on benchmarks of environmental sustainability, Country Office Annual Reports, and reporting on the greening of UNICEF. The current Framework is in the process of being revised and a new version is expected to be finalized this year. Regarding Mozambique, as part of the development of the UNICEF Country Programme (2017-2020) and its Country Programme Document (CPD)[1], UNICEF undertook a situation analysis of all factors related to the situation of children, of disparities and of the factors impeding progress (poverty, climate change and disasters, social norms, weaknesses of social services, legal and policy framework, institutional and financing framework). Specifically, regarding environmental concerns related to WASH, all UNICEF interventions follow Government of Mozambique regulations regarding environmental assessments[3]. For example, confirmation of productivity of boreholes is carried out as part of the preliminary assessment to determine suitability for upgrading to motorized pumps with higher throughput. These confirmations ensure that water sources are sustainably exploited. In addition, all water sources are tested for quality [1] UNICEF CPD 2017-2020 (E/ICEF/2016/P/L.21) was approved by UNICEF Executive Board on its second regular session of 2016 [3] Decreto 45/2004.


according to national standards. Site specific assessments include analysis of risks so final designs are appropriate for potential flooding, storms and other climate related impacts. Moreover, the potential use of solar powered equipment (instead of grid or generator power) is part of the analysis of intervention design development and where possible, has been shown to reduce pollution, improve efficient use of resources and support long-term sustainability of the systems.


4 ANALYSIS OF POTENTIAL ENVIRONMENTAL RISK14 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.15 Potential adverse impacts from water and sanitation activities can be summarized as follows: Potential adverse impacts from water supply activities:

1. Depletion of fresh water resources (surface and groundwater); 2. Chemical degradation of the quality of potable water sources (surface and groundwater); 3. Creation of stagnant (standing) water leading to breading of disease vectors; 4. Degradation of terrestrial, aquatic, and coastal habitats due to continued release of

contaminated water; and, 5. Human health risks from a water source that becomes biologically or chemically contaminated.

Potential adverse impacts from sanitation activities:

1. Increased human health risks from contamination of surface water, groundwater, soil, and food by excreta, chemicals and pathogens; and

2. Ecological harm from degradation of stream, lake, estuarine and marine water quality and degradation of land habitats.

Construction of small-scale sanitation infrastructure may lead to contamination and/or degradation of water sources. Sanitation projects may contaminate or degrade the quality of surface water, ground water, soil, and food, which may result from improper siting of sanitation facilities, improper disposal of excreta or wastewater, improper operation of sanitation facilities, among other causes. However, for small-scale interventions, these impacts can be controlled below the level of significance by appropriate siting, Water Quality Assurance protocols (including regular water testing), design (including drainage and exclusion of livestock from water points) and maintenance. With respect to the latter, capacity-building in equipment/system maintenance is an essential element to construction/installation of small-scale sanitation. During operation, latrines can contaminate high water table, and wells if located in their vicinities, and, when poorly maintained or of an open-pit design, can be the source of proliferation disease vectors such as flies, mosquitoes, spread of diseases, and foul odors. More specifically, poorly designed sanitation facilities can lead to insect-borne diseases, including culex mosquitoes, which do not transmit malaria but can transmit filariasis, breed extensively in septic tanks and flooded latrines. Secondly, flies and cockroaches often thrive on excreta and have been implicated in some transmission of fecal-oral disease. Mosquitoes, flies, and cockroaches all constitute a great nuisance, and poor urban households have consistently been shown to spend substantial amounts of their limited household income on diverse methods for pest control, some of which have health implication of their own.

14 Includes analysis of pertinent environmental (biophysical) and human health & social risk. Climate risk is covered in Sect. 4.2 15 The USAID sector-specific environmental guidelines are good resources in finding more information on potential impacts for various sectors. The following link is to all sector guidelines: https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/sector-environmental-guidelines-resources

https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/sector-environmental-guidelines-resources





Social marketing/education/outreach/community mobilization on hygienic water handling/storage, hand-washing, use of sanitation facilities (CLTS---community-led total sanitation) and the importance of protecting water supplies is, like system and equipment maintenance, an essential corollary to construction and installation of small-scale water and sanitation infrastructure. Experience shows without behavior change, the physical infrastructure will not be used or maintained. Support to access for financing for water and sanitation improvements at household and community levels presents risks if increased finance availability is not accompanied by complementary interventions that better assure that the small-scale/household installations conform to appropriate design and siting criteria, and are properly operated and maintained. Such complementary interventions include, e.g. training local contractors, working with community WASH committees to assure that credit is directed toward well-designed installations, etc. 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. Additionally, 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. Water supply and sanitation activities should be conducted in a manner consistent with the good design and implementation practices described in the Sectoral Guidelines at https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/sector-environmental-guidelines-resources#ws. More specifically, the Mission MUST ensure that implementing partners develop and implement Water Quality Assurance Plans that address how the partner will ensure the provision of safe drinking water to communities served under this activity. This Plan MUST assure that drinking water sources meet local and WHO water quality standards and should be approved by the MEO. An example that IPs can use is available upon request from the MEO. Initial water quality testing is the responsibility of the program to assure, but when feasible, the program should also set in place capacities and responsibilities to provide reasonable assurance that ongoing water quality monitoring occurs16. The standards for initial and ongoing testing -- types of contaminants for which testing should be conducted, testing methods, testing frequency, and issues such as public access to results should follow any applicable USAID guidance, as well as local laws, regulations and policies. Furthermore, a response protocol should be established in the event that water quality testing detects contamination. Among the water quality tests which must be performed are tests for the presence of arsenic. Any USAID-supported activity engaged in the provision of potable water must adhere to Guidance Cable State 98 108651, which requires arsenic testing. The USAID managing team must assure that the standards and testing procedures described in the following document are met: “Guidelines for Determining the Arsenic Content of Ground Water in USAID-Sponsored Well Programs in Sub-Saharan Africa.” POTENTIAL IMPACTS – Component 1: WASH sector governance strengthened

16 Ongoing testing is fundamental to ensure that water is appropriate for human consumption. Explicit recommendation should be made here on the need for ongoing water quality monitoring. Since this is a weakness of the government, the WASH activity (from this conception phase) should consider actions towards building capacity of the local governments to undertake the required ongoing water quality testing.

https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/sector-environmental-guidelines-resources#ws




http://www.encapafrica.org/EGSSAA/Word_English/Watsan.doc







Sub-Intermediate Results Potential environmental and social

impacts Sub-IR1.1: Policy and regulatory framework improved

Nearly all of these activities described in this IR fall under the class of activities not normally considered to have foreseeable environmental impacts, per 22 CFR 216.2(c)(1)(i). Illustrative activities (see Table 2) have no or limited scope of physical interventions and no direct effects on the environment, 22 CFR 216.2(c) (2) recommends a Categorical Exclusion for: (i) Education and training; (ii) Workshops and meetings; (iii) Document and information transfers; (vi) Contributions to national organizations; (v) Programs to develop capacity of host country stakeholders to engage in development planning.

Sub-IR1.2: Institutional capacity to plan, budget, implement and monitor improved Sub-IR1.3: Business climate to attract private sector participation strengthened

POTENTIAL IMPACTS – Component 2: Availability of water and sanitation services increased Sub-Intermediate Results Potential environmental and social impacts

Sub-IR2.1: Consumer-responsive, affordable, women-friendly WASH infrastructure developed or rehabilitated

For any responses which are not exempted or categorically excluded as per 22 CFR216, an ERF/ERR (for subgrants or small activities) or SIEE (for major new programs) must be submitted for approval by USAID.

The AFR Environmental Review Form / Environmental Review Report (ERF/ERR) (available at http://www.usaidgems.org/Documents/ComplianceForms/AFR/AFR-EnvReviewForm-20Dec2010.doc ) must be completed and approved prior to the provision of grants to local groups.

This Sub-IR has the potential to directly or indirectly impact the environment in the following ways:

• Runoff, dust and noise from small-scale construction associated with drilling bore holes, building pipelines, and cleaning and minor rehabilitation of existing, dysfunctional infrastructure for inspection and testing, etc.

• Contamination of ground and surface water through diesel/oil spills associated with construction equipment.

• Depletion of groundwater or surface water when abstraction for new piped water system exceeds replenishment of groundwater/surface water resources,

http://www.usaidgems.org/Documents/ComplianceForms/AFR/AFR-EnvReviewForm-20Dec2010.doc





including cumulative impacts from this project and other projects

• Creation of human health risks from provision of biologically or chemically contaminated water. Even if water is not contaminated initially, it can become so through leaks and corrosions in pipes or in poor management.

• Create stagnant (standing) water in the vicinity of the water supply point and creation of diseases vectors breeding sites (mosquitoes, risks of contamination of fetched water, foot infection of water point users, seepage in and contamination of the wells, etc.)

Sub-IR2.2: Capacity of providers and communities to manage water services improved

No foreseeable direct environmental and social impacts.

Sub-IR2.3: Innovative models for financing and service delivery tested and scaled up

No foreseeable direct environmental and social impacts

POTENTIAL IMPACTS – Component 3: Adoption of Key WASH behaviors accelerated

Sub-Intermediate Result Potential environmental and social impacts Sub-IR3.1:Household demand for sanitation increased

Sanitation projects, including the construction of small-scale sanitation infrastructure, may contaminate or degrade the quality of surface water, ground water, soil, and food, which may be caused by improper siting of sanitation facilities, improper disposal of excreta or wastewater, improper operation of sanitation facilities, among other causes. This contamination can degrade the water quality of streams, lakes, estuaries and land habitats, leading to nutrient contamination, alteration of ecosystem structure and function, and loss of biodiversity. Improper handling and disposal of sewage and fecal sludge from households can contaminate surface water, groundwater, soil and food. In turn, this contamination can lead to disease transmission (and resulting malnutrition), higher infant mortality, reduced economic productivity.

Sub-IR3.2: Key behavioral determinants for poor hygiene outcomes addressed

No foreseeable environmental and social impacts.

Cross-cutting Sub-IR3: Women’s participation in WASH-related decision-making strengthened

No foreseeable environmental and social impacts.


5 ENVIRONMENTAL DETERMINATIONS The following summarizes the environmental determinations based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22CFR216. Specified conditions, in this section and detailed in Section 5, become mandatory obligations of implementation, per ADS 204.

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.

a) 22 CFR 216.2(c)(2)(i), for activities involving education, training, technical assistance or training programs;

b) 22 CFR 216.2(c)(2)(ii), for activities involving controlled experimentation exclusively for the purpose of research and field evaluation which are confined to small areas (for this IEE, defined as an area which is smaller than 4 hectares) and carefully monitored;

c) 22 CFR 216.2(c)(2)(iii), for activities involving analyses, studies, academic or research workshops and meetings;

d) 22 CFR 216.2(c)(2)(v), for activities involving document and information transfers; e) 22 CFR 216.2(c)(2)(viii), for programs involving nutrition, health care, or family planning services

except to the extent designed to include activities directly affecting the environment (such as construction of facilities, water supply systems, waste water treatment, etc.);

f) 22 CFR 216.2(c)(2(xi) Programs of maternal or child feeding conducted under title II of Pub. L. 480; and

g) 22 CFR 216.2(c)(2)(xiv), for studies, projects or programs intended to develop the capability of recipient countries and organizations to engage in development planning.

Negative Determination with Conditions

Activities with potential impacts to the environment 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 mitigation measures to address the potential negative impacts.

Mitigation Measures: ● Conduct or refer to a local water (surface/groundwater) resources assessment (i.e., consider the

quantity and quality available, including current uses); ● Survey for, and avoid, wetlands, estuaries or other ecologically sensitive sites in the project area.

Identify nearby areas that contain endangered species and get professional assessment of species’ sensitivity to construction at site (P&D);

● Consider how the project will impact water flows, particularly in the context of climate change; ● Where the Construction of buildings and structures is taking place the following mitigations

should be undertaken to avoid Damaging sensitive ecosystems and causing erosion and sedimentation:

○ No borrow pits within 50 m of a watercourse; ○ No direct discharges to surface watercourses;


○ No discharge of contaminated substances to surface watercourses. ● Create a community-based operations and maintenance plan that takes into account associated

long-term costs; ● Include focus on proper use and maintenance of the improvement as part of behavior change

and education program; ● Integrate hygiene promotion into program design.

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

● The Mission MUST ensure that implementing partners affecting water supply develop and implement approproiate Water Quality Assurance Plans that address how the partner will ensure the provision of safe drinking water to communities served under this activity. This Plan MUST assure that drinking water sources meet local and WHO water quality standards and should be approved by the MEO.

● SIEEs. Because the application of 22 CFR 216 must be appropriately informed by site-specific conditions and appropriately applied to the specific award/activity, the Design Lead or Agreement/Contracting Officer’s Representative (A/COR) must, upon consultation with the MEO, REA and/or BEO, develop, or direct the IP to develop, Supplemental IEEs (SIEEs) for all activities falling entirely or partially under component 2 of this Mozambique Water, Sanitation and Hygiene (M-WASH) Programmatic IEE (PIEE). These SIEEs must be approved prior to on-the-ground implementation of any actions they cover covered the SIEE. SIEEs may, however, be prepared after the activity is awarded, during the workplan development period for the IEE to best incorporate specific information regarding sites and actions; however, budgets and workplans must provide for full implementation of the conditions established by the SIEE. These SIEEs must:

o Provide additional specific details regarding the activity and its entailed actions,

including location (environmental baseline), and the impacts associated with all actions. o Consolidate all required conditions. For actions addressed by the M-WASH IEE,

Supplemental IEEs must, at a minimum, include the conditions for these actions as established by the M-WASH IEE and confirm that no additional activities are planned for the activity at the time of completion. Additional or more stringent conditions or determinations must be recommended as indicated and documented within the Supplemental IEE.

o Rectify any deferrals from the M-WASH IEE for the planned award/activity (none herein at time of approval of PIEE).

o Define and fully comply with 22 CFR 216 requirements for actions that may not have been addressed in the M-WASH IEE because they were defined during the activity design process rather than at the project level. This includes establishing determinations, and as relevant, conditions for these actions.

o Provide direction for the development of an Environmental Assessment or Scoping Environmental Assessments for actions identified as a Positive Determination.


o Specifically direct the actions of the implementing partners in the development of necessary subsidiary environmental compliance documentation, including: the Environmental Mitigation and Monitoring Plan (EMMP) for actions assigned

a negative determination with conditions in the Supplemental IEE (both new conditions and those reiterated from the M-WASH IEE)

development and implementation of the ERF/ERR for sub-grants and sub-awards. The ERR can become the face sheet for the EMMP.

• Water Supply and Sanitation: Follow environmentally sound practices as outlined in the

USAID Sector Environmental Guidelines – Water Supply and Sanitation. This document can be found at: https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/sector-environmental-guidelines-resources#ws ○ Calculate yield and extraction rates in relation to other area water uses and available

supply; ○ 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 effects of intervention, perhaps by establishing some form of communication with downstream parties. 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 following table summarizes the recommended determinations based on the environmental analysis conducted. Upon approval, these determinations become affirmed, per 22CFR216. Specified conditions, detailed in Section 5, become mandatory obligations of implementation, per ADS 204. ENVIRONMENTAL DETERMINATIONS

Projects/Activities Categorical Exclusion

Negative Det.

Positive Det.

Deferral

IR 1: WASH sector governance strengthened Sub-IR1.1: Policies and regulations improved Sub-IR1.2: Institutional capacity to plan, budget, implement and monitor improved Sub-IR1.3: Business climate to attract private sector participation strengthened






All activities under IR1 as identified on table 1 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: i) Education, technical assistance, or training programs except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.) ii) Analyses, studies, academic or research workshops and meetings.

X

IR 2: Availability of water and basic sanitation services increased Sub-IR2.1: Consumer-responsive, affordable, women-friendly WASH infrastructure developed or rehabilitated Sub-IR2.2: Capacity of providers and communities to manage water services improved Sub-IR2.3: Innovative models for financing and service delivery tested and scaled up

Finance or co-finance the cost of drilling and/or rehabilitating boreholes and small piped systems in select districts and develop a comprehensive approach to managing the service.

X

SIEE

In more densely populated areas, build on the experiences of UNICEF, SNV, WaterAid and others to pilot a market-based sanitation approach, leveraging existing small town sanitation plans in the municipalities where they have been developed.

X

SIEE

Conduct an analysis of the sanitation value chain, including the business models of fecal sludge matter (FSM) providers in order to identify areas for possible WASH-FIN support. Based on the analysis, WASH-FIN will prepare and disseminate key findings expected to feed into the refinement of the FSM sub-sector in Mozambique.

X

Support providers and communities to use innovative monitoring and customer feedback mechanisms.

X

Support the development and completion of financial transactions for water and sanitation provider/operator investments.

X

X

Assist UNICEF and AIAS to structure a Small-town Financing Facility.

X

Support government in exploring viable PPP structures that leverage additional financing and/or management and technical expertise in small town and rural growth centers.

X

X

IR 3: Adoption of key WASH behaviors accelerated Sub-IR3.1: Household demand for sanitation increased Sub-IR3.2: Key behavioral determinants for poor hygiene practices addressed Cross-cutting Sub-IR: Women’s participation in WASH-related decision-making strengthened


Support research to examine how gender norms affect decision making and female leadership roles in WASH and support actions that address identified barriers.

X

Support research to examine how gender norms affect decision making and female leadership roles in WASH and support actions that address identified barriers.

X

Engage female youth, leaders and famous artists/actors to increase the voice of women in WASH advocacy and decision making at household, community and national levels.

X

5.1 CLIMATE RISK MANAGEMENT Mozambique has high vulnerable to the adverse effects of climate change, which is predicted to include rising temperatures, changes in precipitation patterns and sea level rise. Sixty percent of the country’s 26 million population lives in low-lying coastal areas with non-resilient infrastructure; and 80 percent of the population farmers, the vast majority of which are smallholder farmers practicing rain-fed agriculture. Mozambique has suffered devastating droughts and tropical cyclones in the past decade. In the future, climate stressors will further affect food and water security, particularly for the most vulnerable and poor. In Mozambique, mean annual temperatures are expected to rise by 1.5°C to 3°C by 2065 (with increases more pronounced in the interior of the country); rainfall is expected to increase (during December to April) with a delayed start and earlier end of the rainy season, especially in the north; and dry seasons are expected to be longer.17

USAID has developed a number of technical reports,18 resources19 and tools to inform and guide USAID staff on climate risk management and how to design projects and activities integrate climate risk into country strategy, project and activity design. USAID’s Climate Risk Screening and Management Tool20 describes climate risks (see Table 2) as well as adaptive capacity challenges and programming opportunities in water and sanitation sectors. These will be useful in assessing and managing climate risk at the Activity Design level.

Table. Climate Risks to Water, Sanitation and Hygiene Programs

17 USAID. 2017. Impact of Climate Change on Select Value Chains in Mozambique. https://www.climatelinks.org/projects/atlas. 18 USAID. 2014. Climate Change and Water: An annex to the USAID Climate-resilient Development Framework. https://pdf.usaid.gov/pdf_docs/PA00K94M.pdf. 19 https://pages.usaid.gov/E3/GCC/climate-risk-management?utm_source=GCCPNet&utm_campaign=GCCCRM&utm_content=Climate_Risk. 20 USAID. 2017. Climate Risk Screening and Management Tool for Use in Project Design. Pages.97-107.

https://www.climatelinks.org/projects/atlas

https://www.climatelinks.org/projects/atlas

https://pdf.usaid.gov/pdf_docs/PA00K94M.pdf

https://pdf.usaid.gov/pdf_docs/PA00K94M.pdf

https://pages.usaid.gov/E3/GCC/climate-risk-management?utm_source=GCCPNet&utm_campaign=GCCCRM&utm_content=Climate_Risk

https://pages.usaid.gov/E3/GCC/climate-risk-management?utm_source=GCCPNet&utm_campaign=GCCCRM&utm_content=Climate_Risk


USAID ADS Reference 201MAL states that a PAD must contain a summary of the climate risk assessment methodology and the main results of the climate risk assessment. A Climate Risk Matrix (see Annex 3) was developed by the Project Design Team Lead (Nathan Sage), reviewed by the AFR/SRD Climate Adaptation Advisor Colin Quinn and Mission Climate Integration Lead (CIL) Olivia Gilmore; and approved by the AFR Bureau CIL Roopa Karia.

Significant (moderate or high) climate risks to the project include:

• Sea level rise, increased frequency and severity of rainfall, flood events and droughts. • More frequent droughts. Success in strengthening role of private water providers—and the

proliferation of boreholes in peri-urban areas of GRM—may adversely affect groundwater levels, thereby amplifying climate risk to drought-vulnerable communities.

• Unpredictable rainfall patterns may impact watersheds, leading to variations in available water supply and borehole failures due to prolonged drought and declining groundwater levels.

• Increased frequency and severity of flooding may damage or destroy infrastructure – particularly given low quality and poor maintenance of existing infrastructure.

• Increased severity of precipitation and flood events may overflow latrines, contaminate water sources and increase risk of waterborne disease. Increased temperature may also increase waterborne disease infection rates.

• Sea level rise and/or storm surge may introduce salt water into groundwater drinking sources in coastal areas.

The project team will address these risks through a combination of donor coordination; development of results-based indicators that link directly to multi-donor funds for government programs (e.g., PRONASAR); technical assistance to strengthen capacity of governmental and non-governmental water


providers and operators; establishment of a national (geo-referenced) water and sanitation monitoring system; and support to increase WASH finance in operations and maintenance, which will lower water losses from leakages. At the outcome level, the project aims to strengthen women’s empowerment thereby increasing climate resilience capacity at household, community and transformative levels. Climate risk management will continue during the Activity Design as well as Activity Implementation processes.


Component 1: WASH Sector Governance Strengthened


Component 2: Availability of Safe Water and Basic Sanitation Services Increased


Component 2: Availability of Safe Water and Basic Sanitation Services Increased (cont.)


Component 3: Adoption of Key WASH behaviors Accelerated

6 CONDITIONS AND MITIGATION MEASURES

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

During Pre-Award:

Solicitations: The design team, in coordination with the A/CO, will ensure solicitations include environmental compliance requirements and evaluation criteria. A/CO will ensure technical and cost proposal requirements include approach, staffing, and budget sufficient for complying with the terms of this IEE.

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

During Post-Award:


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

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

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

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

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

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

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

USAID Monitoring Oversight: The A/COR or designee, with the support of the cognizant environmental officer(s) (e.g., MEO, REA, BEO), will ensure monitoring of compliance with established requirements (e.g., by desktop reviews, site visits, etc.).

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

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

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


USAID Monitoring Oversight: The A/COR or designee, with the support of the cognizant environmental officer(s) (e.g., MEO, REA, BEO), will ensure monitoring of compliance with established requirements (e.g., by desktop reviews, site visits, etc.).

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

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

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

6.2 AGENCY CONDITIONS Sub-contract Screening: The A/COR will ensure the IP uses an Environmental Screening Tool to screen any sub-grant applications and to aid in the development of EMMPs.

Programmatic IEEs (PIEE): PIEEs stipulate requirements for additional environmental examination of new or country specific projects/activities. The A/COR of any project/activity being implemented under a PIEE will ensure appropriate reviews are conducted, typically through a Supplemental IEE, and approved by the cognizant BEO.

Supplemental IEEs (SIEEs): An SIEE will be prepared for any new project/activity being planned which fall under a PIEE. The SIEE will provide more thorough analysis of the planned activities, additional geographic context and baseline conditions as well as specific mitigation and monitoring requirements.

Other Supplemental Analyses: The A/COR will ensure supplemental environmental analyses that are called for in the IEE are completed and documented.

Resolution of Deferrals: If a deferral of the environmental threshold determination was issued, the A/COR will ensure that the appropriate 22CFR216 environmental analysis and documentation is completed and approved by the BEO before the subject activities are implemented.

Positive Determination: If a Positive Determination threshold determination was made, the A/COR will ensure a Scoping Statement, and if required an Environmental Assessment (EA), is completed and approved by the BEO before the subject activities are implemented.

Compliance with human subject research requirements: The AM, A/COR shall assure that the IP and sub-awardees, -grantees, and -contractors demonstrate completion of all requirements for ethics review


and adequate medical monitoring of human subjects who participate in research trials carried out through this IEE and ensure appropriate records are maintained. All documentation demonstrating completion of required review and approval of human subject trials must be in place prior to initiating any trials and cover the period of performance of the trial as described in the research protocol.

6.3 MITIGATION MEASURES 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. These measures shall provide general direction for completing the project/activity Environmental Mitigation and Monitoring Plan (EMMP) and/or the EA and PERSUAP, if required.

TABLE. SUMMARY OF MITIGATION MEASURES FOR COMPONENTS 2 AND 3

Illustrative Activity Mitigation Measures Finance or co-finance the cost of drilling and/or rehabilitating boreholes and small piped systems in select districts and develop a comprehensive approach to managing the service.

Conduct or refer to a local water (surface/groundwater) resources assessment (i.e., consider the quantity and quality available, including current uses) • Survey for, and avoid, wetlands, estuaries or other ecologically sensitive sites in the project area. Identify nearby areas that contain endangered species and get professional assessment of species’ sensitivity to construction at site (P&D) • Consider how the project will impact water flows, particularly in the context of climate change Where the Construction of buildings and structures is taking place the following mitigations should be undertaken to avoid Damaging sensitive ecosystems and causing erosion and sedimentation:

• No borrow pits within 50 m of a watercourse • No direct discharges to surface watercourses • No discharge of contaminated substances to surface watercourses

In more densely populated areas, build on the experiences of UNICEF, SNV, WaterAid and others to pilot a market-based sanitation approach, leveraging existing small town sanitation plans in the municipalities where they have been developed.

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: https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/sector-environmental-guidelines-resources#ws

• Calculate yield and extraction rates in relation to other area water uses and available supply.

• 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 establishing some form of communication with downstream parties.

• 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:

• https://www.usaid.gov/sites/default/files/documents/1860/ENCAP_VFG-Sanitation_Dec2009.pdf

• https://www.usaid.gov/sites/default/files/documents/1860/ENCAP_VFG-WaterSupply_Dec2009.pdf

Explore the possibility of a district-wide water utility model to manage and maintain small piped systems and hand pumps under the delegated management framework.

Create a community-based operations and maintenance plan that takes into account associated long-term costs

Learn from the successes and challenges of CLTS and the use of Community Participation and Education (Participação e Educação Comunitária) and create new ways to improve uptake of latrine use / reduce open defecation.

The following are conditions and best practices that should be implemented for small 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: https://www.usaid.gov/environmental-procedures/sectoral-environmental-social-best-practices/sector-environmental-guidelines-resources#ws

• Calculate yield and extraction rates in relation to other area water uses and available supply.

• 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 establishing some form of communication with downstream parties.

• 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:

https://www.usaid.gov/sites/default/files/documents/1860/ENCAP_VFG-Sanitation_Dec2009.pdf




https://www.usaid.gov/sites/default/files/documents/1860/ENCAP_VFG-WaterSupply_Dec2009.pdf











• https://www.usaid.gov/sites/default/files/documents/1860/ENCAP_VFG-Sanitation_Dec2009.pdf

• https://www.usaid.gov/sites/default/files/documents/1860/ENCAP_VFG-WaterSupply_Dec2009.pdf

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

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

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

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

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

● Provide support to extractive industries (e.g. mining and quarrying) per FAA 117; ● Promote timber harvesting per FAA 117 and 118; ● Lead to new construction, reconstruction, rehabilitation, or renovation work per §216.2(b)(1); ● Support agro-processing or industrial enterprises per §216.1(b)(4); ● Provide support for regulatory permitting per §216.1(b)(2); ● Lead to privatization of industrial facilities or infrastructure with heavily polluted property per

§216.1(b)(4); ● Procure or use genetically engineered organisms per §216.1(b)(1); and/or ● Assist the procurement (including payment in kind, donations, guarantees of credit) or use

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

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








changes in the activity that might require revision of this environmental analysis and environmental determination.

PROGRAMMATIC INITIAL ENVIRONMENTAL EXAMINATIONSupplemental IEEs (SIEEs), or Environmental Review...

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