What If I Must Go Beyond a Preliminary Assessment? (the example of a USAID EA under Reg. 216)

What If I Must Go Beyond a Preliminary Assessment?

(the example of a USAID EA under Reg. 216)

[DATE][SPEAKERS NAMES]

ENCAP EA-ESD Course: Beyond the Preliminary Assessment. Visit www.encapafrica.org 2

Our focus thus far

To this point, we have focused on Phase I of the EIA process. . .

• Understand proposed activities

• Screen• Conduct preliminary

assessment (if needed)

• Scope• Evaluate baseline situation• Identify & choose alternatives• Identify and characterize

potential impacts of proposed activity and each alternative

• Develop mitigation and monitoring

• Communicate and document

Phase I:Initial inquiries

Phase II:Full EIA (if needed)

Our focus!


Now, we focus on the full EIA

The “full EIA” is Phase II of the EIA process:

• Scope• Evaluate baseline situation• Identify & choose alternatives• Identify and characterize

potential impacts of proposed activity and each alternative

• Develop mitigation and monitoring

• Communicate and document

Phase II:Full EIA (if needed)

New focus!

When is a full EIA needed?

When screening indicates an activity is high risk*

When a preliminary assessment indicates that significant adverse impacts are possible

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*But we still recommend doing a preliminary assessment!


Review: Phase 1

Screen the activity

Based on the nature of the activity what

level of environmental

review is indicated?

Conduct a Preliminary Assessment

A rapid, simplified EIA study using simple tools

(e.g. the USAID IEE)

ACTIVITY IS OF MODERATEOR UNKNOWNRISK

SIGNIFICANT ADVERSE IMPACTS

POSSIBLE

SIGNIFICANT ADVERSE IMPACTS

VERY UNLIKELY

ACTIVITY IS LOW RISK (Based on its nature, very unlikely to have significant adverse impacts)

ACTIVITY IS HIGH RISK (Based on its nature, likely to have significant adverse impacts)

Phase IIPhase IUnderstand proposed activity

Why is the activity being proposed?

What is being proposed?

BEGIN FULL EIA

STUDY

STOP EIA

process


Review: the IEE

Remember, the IEE is USAID’s “Preliminary Assessment” A positive determination triggers an full EIA

Recommendation Reg. 216 terminology

Implications(if IEE is approved)

No significant adverse environmental impacts

NEGATIVEDETERMINATION

Activity passes environmental review

With specified mitigation and monitoring, no significant environmental impacts

NEGATIVEDETERMINATIONWITH CONDITIONS

The activity passes environmental review on the condition that the specified mitigation and monitoring is implemented

Significant adverse environmental impacts are possible

POSITIVEDETERMINATION

Do full EAor redesign activity

Not enough information to evaluate impacts DEFERRAL

You cannot implement the activity until the IEE is finalized


USAID: 2 types of full EIA study

Reg. 216 specifies 2 types of full EIAs:

Used to assess the environmental effects of a specific project or action, e.g.

An EA to assess a single dam or irrigation project

An EA to assess impacts of a gas or oil pipeline

The Environmental Assessment (EA)

Programmatic Environmental Assessment

(PEA)*Used to assess the environmental effects of a class of similar actions, e.g.,

dams, irrigation projects and related water resource development,

sustainable forest management plans

*The term in Reg. 216 is “Program Assessment”

Reg 216 discusses only the content of the EA in detail.

However, the regulation states: “To the extent practicable,the form and content of the PEA will be the same as for EAs.”


How is an EA different than an IEE?

Analysis of environmental impacts is much more detailed

Alternatives must be formally defined. The impacts of each alternative must be analysed, and the results compared. (216.6(c))

USAID must consult with the host country government during preparation and regarding the results (216.6(e))!

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First steps in preparing an EA

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PrepareScopingStatement

PrepareTORs

Assemble Team

2 BEO review

The purpose of scoping is to determine the the significant issues the EA will address.

The deliverable for the scoping process is the scoping statement.

The statement includes:

Scope and significance of issues to be analyzed

Issues that do not need to be addressed

Schedule and format of EA, expertise needed

Public consultation is not required by Reg. 216. However, good EIA practice requires public consultation during scoping.!


First steps in preparing an EA

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PrepareScopingStatement

PrepareTORs

Assemble Team

2 BEO review

The scoping statement must be submitted to and approved by the Bureau Environmental Officer (BEO).

STRONGLY RECOMMENDED:Consult with the BEO before beginning the Scoping process.

Terms of Reference for the EIA team are based on the types of issues and analysis required by the scoping statement

Assemble a team based on the TORs.Frequently requires contracting with one or more experts, or an EIA consulting firm.


The EA outline

Reg. 216 specifies that an EA will contain the following elements:

1. Summary

2. Purpose

3. Comparison of alternatives*

4. Affected Environment

5. Environmental Consequences

6. List of Preparers and appendices

Appendices (as indicated)

*Reg. 216 uses the term: “Alternatives Including the Proposed Action”


Contents of the EA sections

Summary

Purpose

Comparison of alternatives

Affected Environment

EnvironmentalConsequences

List of Preparers

Major conclusions

Areas of controversy

Issues still to be resolved.

Describes the development need or objective that the proposed actions (and its alternatives) are intended to address



Summary

Purpose




List of Preparers

Includes the no action alternative

Explain why certain alternatives were not considered

Present the alternatives considered

NOTE: This is a summary of the analysis presented in “Environmental Consequences”

Include mitigation actions

Compare the environmental impacts of these

alternatives.

Identify the preferred alternative



Summary

Purpose




List of Preparers

“Succinctly” describe the environment of the area(s) to be affected

Note that different alternatives may affect different geographic areas or aspects of the environment. The description here must cover all alternatives

Descriptions shall be “no longer than is necessary to understand the effects of

the alternatives”

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Summary

Purpose




List of Preparers

Includes the proposed action and the no action alternative

Impacts of alternatives are not compared.

Should include*

• Any adverse effects and their significance (including those that cannot be avoided)

• Relationship between short-term uses of the environment and maintenance/ enhancement of long-term productivity

• Conflicts with other policies, plans or controls for the areas under consideration

• Recommended mitigation measures

Presents the environmental impacts of each alternative

*See 216.6.(c)(5) for full list


NOTE: WHEN ASSESSING IMPACTS,TOO MUCH INFORMATION IS AS BAD AS NOT ENOUGH

Provide the most detailed analysis for the more significant impacts.

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Summarize or reference for lesser impacts

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*See 216.6.(c)(4)



Summary

Purpose




List of Preparers

Names and qualifications of the EA Team

Annexes can be useful in organizing the EA so that only the most critical information for decision-making is in the body of the EA


Coordination with host country procedures

What are the implications? USAID projects must satisfy BOTH Reg. 216 AND host

country procedures One EIA document should be created to satisfy both

procedures Will require discussions in the scoping process with host

country EIA regulatory agency.

The large majority of host countries now have EIA policies and procedures

Most projects that require an EA under Reg. 216 will also require a full EIA under host country procedures

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Gaps in the Reg. 216 EA requirements

Reg. 216 does not have language that emphasizes the importance of a detailed mitigation and monitoring plan

However, Mitigation and Monitoring Plans are essential to making the EA effective

Remember, Mitigation and Monitoring plans assign responsibilities and establish schedules/time lines and reporting requirements.

What If I Must Go Beyond a Preliminary Assessment? (the example of a USAID EA under Reg. 216)

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