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INITIAL ENVIRONMENTAL EXAMINATIONACTIVITY DATA

Activity Name: USAID Food for Peace (FFP) FY19 Request for Applications (RFA) for Development Food Security Activities in Madagascar and Malawi

Amendment (Y/N): NGeographic Location(s)

(Country/Region):Southern and Eastern Madagascar1 and Southern

Malawi2 Implementation Start/End: Pre-Award, To be determined upon award(s)Solicitation/Contract/Award Number:To be determined Implementing Partner(s): To be determined upon award(s)Link to IEE: DCHA FFP FY19 RFA IEELink to Other, Related Analyses: Malawi- 118/119, Mission PERSUAP, Climate Risks

Madagascar - 118/119, FFP PERSUAP, Climate Risks

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

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

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

Same as above

Funding Account(s): Title II, Community Development Funds (CDF)Funding Amount: Madagascar: $90 million (Title II)

Malawi: $75 million (CDF)Other Affected Unit(s): Africa Bureau, Southern Africa Regional Mission

(Pretoria)Lead BEO Bureau: Democracy, Conflict and Humanitarian Assistance

(DCHA)Prepared by: Environmental Compliance Support (ECOS)

contract Date Prepared: March 2019

ENVIRONMENTAL COMPLIANCE REVIEW DATAAnalysis Type: Initial Environmental ExaminationEnvironmental Determination(s): Positive Determination, DeferralIEE Expiration Date: 2023, End of AwardsAdditional Analyses/Reporting Required:

Implementing partners to develop Supplemental IEEs

Climate Risk Rating: Low __X___ Moderate __X___ High __X___1 Atsimo Atsinanana, Vatovavy-Fitovinany, Androy regions. Ampanihy, Betioky, and Toliara II districts (Atsimo Andrefana region)2 Mangochi, Blantyre, Neno, and Zomba districts

FY 19 Madagascar and Malawi RFA IEE 1

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

ACTIVITY SUMMARYAs specified in the Country Specific Information (CSI) for Madagascar and Malawi these activities will contribute to the achievement of resilience and economic and social development plans while reducing food insecurity in the target countries.

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

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

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

BEO SPECIFIED CONDITIONS OF APPROVALCondition 1: Applicant to submit Environmental Safeguards Plan.Condition 2: Awardee to develop Supplemental IEE for Mission and Washington

clearance4.Condition 3: Implement environmental monitoring requirements. This includes

development and alignment of Environmental Mitigation and Monitoring Plan (EMMP) with performance M&E systems.

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

3 Word versions of the required templates can be found at a Google drive here: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8 4 The supplemental IEE can also be referred to as the “activity-level IEE”5 The ESR is similar to the Environmental Mitigation and Monitoring Report (EMMR) used elsewhere in USAID. However, the ESR meets purposes of annual reporting and budget planning for environmental compliance.

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

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

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

Condition 8: Ensure compliance with partner country environmental regulations.

IMPLEMENTATIONIn accordance with 22 CFR 216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Sections 3, 4, and 5 of the IEE, including any BEO-specified Conditions.

USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATION

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

Bureau Tracking ID: DCHA FFP FY19 RFA IEE Madagascar-Malawi

Approval: ___________________________________________Matthew Nims, FFP Deputy Director

____________Date

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

____________Date

Clearance: ___________________________________________Kyle Rearick, DCHA Climate Integration Lead

____________Date

Concurrence:

___________________________________________Erika J. Clesceri, DCHA Bureau Environmental Officer

____________Date

DISTRIBUTION:

Field: Aaron Brownell (REO, Southern Africa); Madagascar: Salohy Soloarivelo (MEO), Jacky Ralaiarivony (dMEO), Carrie Antal (Director, office of Food Security Disaster Assistance),Jessie Snaza (CIL), Serge Ramanantsoa (Deputy CIL); Malawi: Robert Matengula (Malawi MEO/CIL), Emmanuel Nglube (FFP Officer), Killian Mutiro (FFP Officer, USAID South Africa), Joseph Mwangi (Activity Manager), Lucy Mungoni (WASH Advisor).

Washington: Brian Hirsch (Africa BEO), Walter Knausenberger (Senior Advisor, Africa Bureau), Allison Brown (Environmental Advisor, Africa), Roopa Karia (CIL, Africa Bureau), William Thomas (BFS BEO) and Etienne Yonly (FFP Grants Management Specialist), Melanie Chamberlain (FFP Officer-Madagascar), Fadumo Tahlil (FFP Officer-Malawi)

FFP/W: Dan Houston (Design), Arif Rashid (M&E), Adam Reinhart (Tech), Elizabeth Bontrager (Nutrition),

TABLE OF CONTENTS

1.0 ACTIVITY DESCRIPTION1.1 PURPOSE AND SCOPE OF IEE1.2 ACTIVITY OVERVIEW1.3 ACTIVITY DESCRIPTION

2.0 BASELINE ENVIRONMENTAL INFORMATION2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL)2.2 APPLICABLE AND APPROPRIATE PARTNER COUNTRY AND OTHER INTERNATIONAL STANDARDS, ENVIRONMENTAL AND SOCIAL LAWS, POLICIES, AND REGULATIONS 19

3.0 ANALYSIS OF POTENTIAL ENVIRONMENTAL AND CLIMATE RISK 223.1 ENVIRONMENTAL IMPACTS OF COMMODITY FUMIGATION 223.2 CLIMATE RISKS TO COMMODITY FUMIGATION 233.3 OTHER FFP PROGRAM AREAS AND ELEMENTS 23

4.0 ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATING 244.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS 244.2 RECOMMENDED CLIMATE RISK RATING 24

5.0 CONDITIONS AND MITIGATION MEASURES 255.1 CONDITIONS 25

6.0 LIMITATIONS OF THIS INITIAL ENVIRONMENTAL EXAMINATION 377.0 REVISIONS 38ATTACHMENTS: 39ANNEX 1: TEMPLATE FOR SUPPLEMENTAL INITIAL ENVIRONMENTAL EXAMINATIONS

40ANNEX 2: TEMPLATE FOR ENVIRONMENTAL MITIGATION AND MONITORING PLANS 50ANNEX 3: GUIDANCE FOR DEVELOPMENT OF AN INSTITUTIONAL ARRANGEMENT PLAN 51ANNEX 4: TEMPLATE FOR ENVIRONMENTAL STATUS REPORTS 55ANNEX 5: GUIDANCE FOR CLIMATE RISK MANAGEMENT SCREENING 63ANNEX 6: CLIMATE RISK MANAGEMENT SUMMARY TABLE 67

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

This RFA IEE is a critical element of USAID’s mandatory environmental review and compliance process meant to achieve environmentally sound activity design and implementation. This RFA IEE, cleared by FFP Washington, also establishes the requirements for post-award implementing partners (IPs) to develop their own Supplemental IEEs for Mission clearance and outlines other BEO-specified Conditions for implementation and reporting throughout the life of the awards.

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

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

As specified in the Country Specific Information (CSI) for Madagascar and Malawi Development Food Security Activities, FFP investments in the target FFP geographies67 will contribute to USAID’s FFP Strategy by strengthening community resilience, protecting and enhancing livelihoods, and improving food and nutritional security of vulnerable households.

1.3 ACTIVITY DESCRIPTIONFFP development food security activities in Madagascar and Malawi are intended to build resilience in populations vulnerable to chronic hunger and repeated hunger crises, and to reduce their future need for ongoing or emergency food assistance. To these ends, the FFP office supports the procurement, protection, and distribution of food commodity, including fumigation, as well as a range of program areas and elements.

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

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

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

TABLE 1: PROGRAM AREAS OR ELEMENTS Commodity FumigationOther FFP Program Areas or Elements Civil society HIV/AIDS Maternal and child health Family planning and reproductive health

6 Madagascar: Atsimo Atsinanana, Vatovavy-Fitovinany, Androy regions. Ampanihy, Betioky, and Toliara II districts (Atsimo Andrefana region)7 Malawi: Mangochi, Blantyre, Neno, and Zomba districts

Water supply and sanitation Environment Climate change – adaptation Climate change - clean energy Nutrition Basic education Social assistance Agriculture Private sector productivity Financial sector Protection, assistance and solutions Disaster readiness

2.0 BASELINE ENVIRONMENTAL INFORMATION2.1 LOCATIONS AFFECTED AND ENVIRONMENTAL CONTEXT (ENVIRONMENT, PHYSICAL, CLIMATE, SOCIAL)Implementing partners are expected to design their programs to address intervention area-specific biophysical, socioeconomic and cultural conditions, as well as the political and institutional context in which the development food security activities will operate. Applicants are expected to draw from existing USAID or other country-level environmental analyses, including USAID climate change vulnerability and adaptation analyses, (which can be found by searching for Malawi and/or Madagascar in the Climatelinks resource library), Foreign Assistance Act (FAA) 118/119 Biodiversity and Tropical Forestry Assessments, and Country Specific Information reports.

The following sub-sections provide a brief overview of the baseline climate and environmental information for Madagascar and Malawi, pertinent to the sub-national areas in the FFP geographies. It is crucial to understand the baseline situation (the existing environmental situation or condition in the absence of USAID activities) in order to understand and measure the impacts, or change from the baseline, caused by the activity.

Madagascar:

● Climate Risks

● Key Ecological Habitats

● PERSUAP and Pesticides

● Invasive Species

● Water Resources

Malawi:

● Climate Risks

● Key Ecological Habitats

● PERSUAP and Pesticides

● Invasive Species

● Water Resources

MADAGASCARMADAGASCAR CLIMATE RISKSMadagascar’s climate is tropical, with two distinct seasons: a hot rainy season from November to April and a dry season from May to October. Rainfall varies regionally, but annual average rainfall is 1,500 mm. The eastern region is the wettest, and the southwest is the driest. Average annual temperatures are 23°C–27°C along the coast and 16°C–19°C in the highlands. In the southeast, the Atsimo Atsinanana and Vatovavy-Fitovinany regions experience high but irregular rainfall and average temperatures ranging from 10°C to 32°C. The main climate hazards common to these areas are cyclones and floods. In the south and southwest, the Atsimo Andrefana and Androy regions are characterized by a semiarid tropical climate and average annual rainfall of 300-600 mm, mostly concentrated from December to March. Droughts, floods, and heat waves are the most frequent climate hazards, although normal average temperatures typically range from 20°C to 35°C.

According to USAID’s countrywide Climate Risks in Food for Peace Geographies - Madagascar (2018), the island is highly vulnerable to future climate shocks, such as increasing frequency or intensity of extreme weather events like cyclones and drought, and slower onset climate changes, such as increased temperatures, all of which are expected to reduce agricultural yield and exacerbate food insecurity. A critical risk where agriculture serves as the main source of income for over 80 percent of the Malagasy population.

In recent years, the agricultural sector has been hit particularly hard by extreme weather events. Rice production has fallen by an estimated 20 percent relative to 2016, and dry spells in 2018 have also diminished harvests and reduced food production.8

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

MADAGASCAR KEY ECOLOGICAL HABITATSThe FFP geographic zones in the Atsimo Andrefana and Androy regions contain ecosystems that serve as important sources of biodiversity. See Figure 1, which shows the districts targeted by FFP and their proximity to protected areas. Ecosystem services provide vital benefits to communities, such as water provisioning, carbon sequestration, and flood prevention. Healthy and well-managed ecosystems play an important role in enhancing the resilience of communities to shocks. According to the Journey to Self-Reliance, FY 2019 Country Roadmap for Madagascar, Madagascar receives a score of 0.35 out of 1 for Biodiversity and Habitat Protection. This metric is drawn from the Yale University/Columbia University Center for International Earth Science Information 8 USAID. 2018. Food Assistance Fact Sheet - Madagascar.

Network (CIESIN) Environmental Performance Index (EPI) to evaluate a country's performance in habitat conservation and species protection.

Madagascar’s long coastline supports valuable ecosystems including coral reefs, littoral forests, mangroves and wetlands, which also provide important ecosystem services such as storm buffering and absorbing carbon. Madagascar has 20 Ramsar sites, including the Nosy Ve Androka barrier reef Ramsar Site in the FFP zone of influence in the Atsimo Andrefana region, which is home to a cluster of important marine habitats. Madagascar is currently losing wetlands faster than forests due to conversion for rice farming and siltation from deforestation9.10 There are also numerous protected areas and conservation corridors that overlap with the FFP zones of influence, such as the “Paysage Mikea” and “Paysage Plateau Mahafaly Karimbola” in the Atsimo Andrefana and Androy regions. The Madagascar 118/119 assessment provides an overview of these parks and conservation areas, which can be mapped with FFP zones of influence. Deforestation is a particularly serious threat to the western dry forests of the Atsimo Andrefana region, where the rate of deforestation reached 0.8 percent from 2005-2010.11 Madagascar is also home to several threatened species, such as the critically endangered Fish Eagle and Sacred Ibis. FFP projects should ensure that Supplemental IEEs address any potential overlap between FFP zones of influence and endangered species’ ranges.

9 Climate Risks in Food for Peace Geographies - Madagascar 10 Climate Risks in Food for Peace Geographies - Madagascar 11 USAID. 2014. Madagascar Environmental Threats and Opportunities Assessment.

Figure 1. Map of FFP Geographies* and Protected Areas in Madagascar; Sources: Political boundaries: Natural Earth (www.NaturalEarthData.com). Protection areas: Protection Planet (https://www.protectedplanet.net/)

*District outlines. Specific Orientation within districts to be determined.

USAID’s FAA 118/119 for Madagascar12 states that the country- as a whole- is facing significant environmental challenges that are accelerating the depletion of natural resources and threatening biodiversity. Primary threats to biodiversity include: 1) illegal logging, 2) slash-and-burn cultivation, 3) wildlife trafficking, 4) unsustainable resource use, 5) over-exploitation of bushmeat, 6) unregulated mining, 7) erosion, 8) wildfire, 9) climate risks, and 10) population pressure. Deforestation is a particularly serious threat to the western dry forests of the Atsimo Andrefana region, where the rate of deforestation reached 0.8 percent from 2005-2010.13 These environmental threats are compounded by the country’s overall lack of capacity to manage environmental resources and enforce environmental regulations.

MADAGASCAR PERSUAP AND PESTICIDESMadagascar’s increased intensity of rainfall may increase the risk of contamination and reduce pesticide effectiveness in areas characterized by poor soils, such as Atsimo Andrefana and Androy (Climate Risks in Food for Peace Geographies). The country primarily employs large-scale applications of insecticides to mitigate hazards both to both public health and the agricultural industry. Madagascar has implemented a National Plague Control Program that dusts households with insecticides to limit disease vectors and prevent the expansion of epidemics. The entire population of Madagascar is highly susceptible to malaria, which the country has been combating with insecticides for many years. However, the mosquitoes that act as major vectors to malaria have displayed a resistance to insecticides like DDT and pyrethroids, which limits the success of indoor spraying efforts.14

12 USAID. 2014. Madagascar Environmental Threats and Opportunities Assessment.The Madagascar Environmental Threats and Opportunities Assessment, also called the 118/119 in reference to Sections 118 and 119 of the Foreign Assistance Act (FAA).13 USAID. 2014. Madagascar Environmental Threats and Opportunities Assessment.14 President’s Malaria Initiative. 2016. The PMI AIRS Project Semi Annual Report April 1, 2016-September 30, 2016.

In addition, Madagascar is particularly at risk of plague, a rodent disease that can be transmitted to humans by infected flea bites.15 The country has experienced two recent outbreaks of plague in 2014 and 2017, the latter outbreak resulting in approximately 202 deaths.1617 Similar to the mosquito population, fleas in Madagascar have developed a resistance to 11 common insecticides.18 It is possible that officials will respond to these species’ growing chemical resistances by increasing or diversifying pesticide use. Vector borne diseases, such as those described above, distribution and seasonality may shift due to changes in climate, such as increased temperatures or changing rainfall patterns, and land use change, such as deforestation. For example, erratic rainfall and temperature changes has led to the emergence of fall armyworm as a new pest challenge, including in the Atsimo Andrefana and Androy regions.

Climate stressors could also increase the contamination hazard to humans from agricultural pesticides. Farmers in Madagascar use chemicals to fertilize their soil, as well as to combat pests that threaten crops, such as locusts. In 2013, the Ministry of Agriculture and Livestock in partnership with FAO launched a three-year insecticide campaign to battle a locust outbreak.19 The campaign employed pesticides such as chlorpyrifos 240 ULV, teflubenzuron (an Insect Growth Regulator or IRG), Green Muscle (a fungal biopesticide) and imidacloprid (Gaucho 70 WS). In November 2017, Madagascar also had its first reporting of fall armyworm, an invasive pest that causes damage to crops. The introduction of fall armyworm in Madagascar may increase the potential risk of exposure to toxic chemicals for millions of people, as farmers attempt to protect their crops by using synthetic pesticides.20 That risk is likely to grow further as heightened intensity of heavy rainfall combined with poor soil leads to increased runoff of contaminated water.

Limited oversight and regulation have also led to a proliferation of dangerous or outdated chemical products throughout the country. All of these impacts and factors should be considered in the Supplemental IEE. FFP activities in Madagascar should also develop a tiered-off Safer Use Action Plan (SUAP) from the existing FFP PERSUAP in Madagascar that is specific to the activities supporting pesticide use. See below on PERSUAPs for more information on pesticide use, e.g. fumigation, agriculture, livestock, and construction.

MADAGASCAR INVASIVE SPECIESIn Madagascar, invasive species are often highly adaptable and can respond positively to rising temperatures and variable climate conditions, according to the 15 Miarinjara, A., Boyer, S. 2016. Current Perspectives on Plague Vector Control in Madagascar: Susceptibility Status of Xenopsylla cheopis to 12 Insecticides.16 WHO. 2014. Plague - Madagascar.17 WHO. 2017. Plague - Madagascar.18 Miarinjara, A., Boyer, S. 2016. Current Perspectives on Plague Vector Control in Madagascar: Susceptibility Status of Xenopsylla cheopis to 12 Insecticides.19 FAO. Accessed 2018. Madagascar Locust Crisis.20 FAO. 2018. Fall Armyworm Prevalence Assessment in Madagascar.

Climate Risks in Food for Peace Geographies. Some initiatives have even promoted certain invasive species because of these very characteristics, to the detriment of land productivity, biodiversity and ecosystem function, creating economic damage and costly removal efforts.

FFP projects are specifically prohibited from using USAID support for promotion of any invasive species. Non-native species that have been introduced to Madagascar by humans have rapidly expanded their range, resulting in both negative and positive effects on ecosystems and native biodiversity. Moreover, substantial evidence suggests that climate change is likely to increase the likelihood of invasive species taking hold and spreading across forests and rangelands. Some invasive species known to be present in Southern Madagascar are:

● Opuntia (prickly pear): Species of cacti ranging from small, low-growing shrubs to specimens of 16 feet or more;21 used by farmers to create natural borders and enclosures. However, also encroaches on agricultural land and pastures, hindering productivity.

● Acacia dealbata: Evergreen, fast-growing, cold-tolerant, and nitrogen-fixing shrub or tree with a moderate to deep root system.22 Grows in cooler highland or foothill regions. Seed persistence, multiple seed dispersion mechanisms (water, ants, wind), and ability to thrive in similar environments (e.g., southern Africa) may make this plant an ecological problem for Madagascar.23

● Eichorniae crassipes: (water hyacinth) Aquatic species of a few centimeters to over a meter in height; forms dense floating mats that impede water flow and create mosquito breeding areas. Adapted to temperature range of 12-35C, seeds can germinate in a few days or remain dormant for 15-20 years to survive variable conditions.

MADAGASCAR WATER RESOURCESThe Madagascar WASH Sector Key Results Framework (2016-2019) reported that an estimated 65 percent of rural households do not have access to a safe water supply, and 88 percent of the population does not have access to water sanitation. For example, in Tshiombe (Androy region), most residents dig shallow wells in the Manambovo riverbed to access water. Water quality in Madagascar is threatened by climate risks such as longer dry periods, cyclones and heavy rainfall events, and sea level rise. Extended drought is likely to cause water sources to dry up, reduce good hygiene practices that prevent the spread of disease, and accelerate the spread of airborne fecal dust in areas where the population still practices open defecation. For example, in Tshiombe, rivers, wells and water tanks often fail 21 Encyclopedia Britannica. Accessed 2018. Opuntia.22 Florabank. Accessed 2018. Acacia dealbata.23 Kull, C.A., et al. 2007. Invasive Australian acacias on western Indian Ocean islands: a historical and ecological perspective.

during droughts. Moreover, increasingly frequent and severe weather events may exacerbate flood damage and water supply contamination, increasing the incidence of waterborne disease.24 Madagascar’s coastal aquifers have already experienced substantial salinization that could be heightened further by future sea level rise, reduced rainfall, and/or longer dry periods. In 2013, Cyclone Haruna ruptured a dike in Toliara (Atsimo Andrefana region), leading to fooding that damaged water supplies, amongst other infrastructure. According to the British Geological Society, little information is available about potential chemical contamination of Madagascar’s groundwaters, but in some areas, deeper aquifers are affected by high salinity and high iron. Shallow groundwater also has the potential to be impacted by sewage wastes.

24 USAID. 2018. Climate Risks in Urban and Urbanizing Geographies - Madagascar. FY 19 Madagascar and Malawi RFA IEE

MALAWIMALAWI CLIMATE RISKSAs outlined in the Climate Risks in Food for Peace Geographies - Malawi, most of Malawi experiences a tropical continental climate, with a rainy season (November to April) and dry season (May to October). Annual rainfall varies regionally from about 500 mm up to 3,000 mm. Southern Malawi, where FFP zones are located, is drier than the central and northern regions. The south is also characterized by higher temperatures, which range from 9°C to 39°C, on average. Drought and floods occur almost yearly. Dry spells and droughts are occasionally amplified by El Niño Southern Oscillation events. Country-wide, temperatures are expected to increase by an additional 1.0 -3.0 C by 2050, with increased frequency and intensity of flooding and droughts, especially in the south.

These climate stressors are likely to negatively affect agriculture, a particularly significant problem since Malawi is a primarily agrarian society and the vast majority of its population relies on agriculture for income. The agricultural sector – both crop and livestock production – is heavily dependent on rainfall as the main source of water, as only 5 percent of arable land is irrigated.25 The agricultural sector is dominated by maize, which is grown by more than 95 percent of farmers. Maize is highly sensitive to drought, making it extremely vulnerable to climate variability. Climate trends could negatively impact productivity in the FFP zones. Malawi experiences a variety of climate hazards that negatively affect crop production and are likely to become more frequent, including intense rainfall, floods, seasonal droughts, and landslides.26 In addition to harsh climate conditions, declining soil fertility and a rapidly increasing population in the southern region put further pressure on arable land challenge crop production. Agriculture has shrunk as a share of GDP, from 40 percent in 2002 to 26 percent in 2017, mainly due to prolonged dry spells and pest infestations.

Malawi has encouraged expansion of livestock production as a means of diversifying income sources and as a mitigation measure against climate variability. Livestock is substantially more resilient to climate variability than crop production, although climate stressors may negatively affect livestock production due to higher disease prevalence and reduced forage availability.27 Rising temperatures are likely to increase livestock exposure to heat stress, as well as increase the incidence of diseases such as worms and orf virus in goats and Newcastle disease in chickens. In addition, severe flooding events can lead to significant livestock losses, as well as reducing total yield of feed crops and forage.2829

25 FAO. Accessed 2018. Economic and Policy Analysis of Climate Change - Malawi.26 UNDP. Accessed 2018. Climate Change Adaptation - Malawi.27 FAO. 2017. Tackling climate change in Zambia and Malawi.28 Government of Malawi. 2015. Malawi 2015 Floods Post Disaster Needs Assessment Report.29 Rojas-Downing M. et al. 2017. Climate change and livestock: impacts, adaptation, and mitigation.

MALAWI KEY ECOLOGICAL HABITATSOf the four geographic zones where FFP activities will be clustered, the Districts of Mangochi, Blantyre and Zomba, have a close proximity to ecological habitat that maintain some level of country or international significance. See Figure 2, which shows the districts targeted by FFP and their proximity to protected areas. Ecosystem services provide vital benefits to communities, such as water provisioning, carbon sequestration, and flood prevention. Healthy and well-managed ecosystems play an important role in enhancing the resilience of communities to shocks. According to the Journey to Self-Reliance, FY 2019 Country Roadmap for Malawi, Malawi receives a score of 0.91 out of 1 for Biodiversity and Habitat Protection. This metric is drawn from the Yale University/Columbia University Center for International Earth Science Information Network (CIESIN) Environmental Performance Index (EPI) to evaluate a country's performance in habitat conservation and species protection.

As described in the FAA 118/119 for Malawi (2012), threats to Malawi’s ecosystems stem from three common themes: 1) lack of affordable household energy, which is a main driver of deforestation and forest degradation; 2) limited national and household economic growth, which causes issues such as mining in protected areas; and 3) unsustainable practices, including overfishing, illegal timber harvesting, and wildlife poaching.

The FFP geographic zone in Zomba District contains important aquatic ecosystems, a prominent type of habitat in Malawi that comprises 22 percent of the country’s total surface area. For instance, Lake Chilwa in the Zomba District, is designated as a protected wetland area under the Malawi Ramsar Convention on Wetlands of International Importance, to which Malawi is a party. Malawi contains additional Ramsar sites, but they are not described here because they are not in FFP geographies. Wetland ecosystems provide many environmental benefits, including regulating stream flow, purifying water, and providing a habitat for biodiversity. Unfortunately, Malawi’s

Figure 2. Map of FFP Geographies* and Protected Areas in Malawi; Sources: Political boundaries: Natural Earth (www.NaturalEarthData.com). Protection areas: Protection Planet (https://www.protectedplanet.net/)

*District outlines. Specific Orientation within districts to be determined

wetlands are threatened by poor ecosystem management practices, such as the expansion of agricultural land into wetland areas.

In addition to wetlands, the FFP zone in Mangochi District includes Lake Malawi National Park, a protected UNESCO World Heritage Site and a globally important location for biodiversity conservation. Lake Malawi serves as the habitat for the largest number of fish species of any lake in the world, as well as many species of mammals, birds, and reptiles. Although Lake Malawi National Park’s terrestrial and underwater habitats are presently in good condition, the area still faces threats from a growing human population, overcollection of firewood, fish poaching, and crowded fish landing sites.30 Similar hazards also affect Liwonde National Park (which includes a section of the shore of Lake Malombe) in Mangochi District. Liwonde and Lake Malombe are home to many important species, such as African elephants and various endemic fish, but there have been serious poaching incidents in these areas.31

There are also other important ecological areas that overlap with FFP zones of influence, such as Mulanje Mountain Biosphere Reserve near Blantyre.32 The Mulanje Cedar (endemic tree species) is only found on this mountain where it has adapted to the mountain’s particular conditions, but is highlight threatened by overexploitation and illegal harvest. Similarly, Zomba District is home to the Zomba Forest Reserve and Malosa Forest Reserve, which serve as major sources of wood and water for most residents of Zomba. However, ever-increasing demand for forest resources (charcoal, timber, firewood, etc.) has led to an unsustainable depletion of several tree species in these areas.33 Some ecologically important areas, including national parks, are home to threatened, endangered and rare species. FFP projects should ensure that Supplemental IEEs address any potential overlap between FFP zones of influence and endangered species’ ranges.

Well-managed ecosystems--including wetlands, forests, and coastal systems--can enhance environmental resilience by acting as natural infrastructure features, reducing the risks posed by disasters such as floods. To read more about how natural features of the environment can mitigate disaster risk, visit the International Union for Conservation of Nature’s Eco-Disaster Risk Reduction and the joint WWF-USAID guidance on Natural & Nature-based Flood Management.

MALAWI PERSUAP AND PESTICIDESChemical pesticide use is low at the household level in Malawi. Most pesticide use occurs on large estate farms that produce export crops such as tobacco, tea, and sugar cane. However, pesticide use is posing new challenges for Malawi, as climate change exacerbates existing risks. In 2018, Malawi experienced a widespread

30 UNESCO. Accessed 2019. Lake Malawi National Park.31 Government of Malawi. 2011. Second National Communication to the United Nations Framework Convention on Climate Change.32 UNESCO. Mulanje Mountain Biosphere Reserve.33 Government of Malawi. Accessed 2019. Zomba-Malosa Forest Reserve Impact Area; Zomba District.

infestation of fall armyworm that affected more than 380,000 ha of maize, sorghum, and millet, destroying approximately 10 percent of the year’s maize crop and affecting over 1 million farm families.34 In response to that outbreak, the Malawi government began prioritizing pesticide distribution, however, increased pesticide use presents environmental and health risks to untrained farmers and extension workers. About 1-3 percent of agricultural workers suffer from acute pesticide poisoning. Climate stressors may further increase these risks, as more intense rainfall and frequent flooding could spread pesticides through runoff, particularly in areas with poor soils, such as Blantyre and Neno in the Middle Shire Valley. Research has also indicated existing surface water contamination by the herbicides atrazine and metolachlor in Zomba District, a problem that may be exacerbated by potential future increases in precipitation.35

The adverse effects of climate variability may also create incentives for farmers to use larger amounts of pesticides. Rising temperatures are likely to lead to rising heat stress and more abundant insect pest populations, both of which may reduce crop yields, motivating farmers to increase their use of pesticides.36 In addition, Malawi faces the challenge of a black market for unregulated or illegal chemical pesticides, which poses the threat of introducing highly toxic substances into the natural environment.37 An increase in pesticide use, especially of dangerous unregulated chemicals, exacerbates the threat of exposure through air, soil, and water. All of these impacts and factors should be considered in the IEE. FFP programs in Malawi will also need to developed a tiered-off SUAP (based on the Malawi mission-wide PERSUAP) that is specific to the activities supporting pesticide use. See below on PERSUAPs for more information on pesticide use, e.g. fumigation, agriculture, livestock, and construction.

MALAWI INVASIVE SPECIESAs stated in the Foreign Assistance Act of 1961, USAID is responsible for ensuring that U.S. assistance programs do not lead to the introduction of invasive species in other nations. As such, USAID does not support activities that promote the introduction of invasive species, where there is any reasonable chance that this may facilitate their introduction or spread within a protected area. FFP projects are specifically prohibited from using USAID support for promotion of any invasive species.

The Climate Risks in Food for Peace Geographies - Malawi reports that there were 31 invasive species in Malawi in 2014. Moreover, future climate variability is likely to lead to an expansion of many varieties of invasive plants and pests in Malawi. FFP projects are specifically prohibited from using USAID support for promotion of 34 International Food Policy Research Institute. 2018. Malawi’s new reality: Fall armyworm is here to stay.35 Deliwe Dinah Lakudzala. 2013. Atrazine and metolachlor contamination in surface and ground water in the Zomba/Bvumbwe region in Malawi.36 Gatto, M., Cabella, R., and Gherardi, M. 2016. Climate change: the potential impact on occupational exposure to pesticides.37 Government of Malawi. 2017. Pest Management Plan.

any invasive species. Invasive species--both insects and plants--can cause significant crop and livestock losses, as well as displacing native biodiversity. Malawi is estimated to have lost between 7.0-9.3 percent of agricultural GDP from major invasive species damage to crops.38 In addition, invasive plant species such as Prosopis juliflora (which is present in Malawi) are known to increase prevalence of malaria in Africa, as their flowering branches are highly attractive to mosquitoes and provide nectar throughout the year.39 Species known to be present in Southern Malawi include:

● Eichorniae crassipes: (water hyacinth) Aquatic species of a few centimeters to over a meter in height; forms dense floating mats that impede water flow and create mosquito breeding areas. Adapted to temperature range of 12-35C, seeds can germinate in a few days or remain dormant for 15-20 years to survive variable conditions.

● Prosopis juliflora: Perennial, deciduous, fast-growing, nitrogen-fixing and very salt- and drought tolerant shrub or tree with deep tap roots; grows in arid and semi-arid environments, forms dense stands and outcompetes native vegetation.

● Parthenium hysterophorus: (Santa Maria feverfew) Noxious, annual, herbaceous weed known for its vigorous growth, especially in warmer climates. Typically grows from 0.5-1.5 meters tall and produces clusters of small, white flowers;40 poses a threat to agriculture, as the roots exude chemicals that interfere with the surrounding plants and the pollen and dust cause systemic toxicity in livestock, as well as allergic contact dermatitis in humans.41

38 Pratt, C. et al. 2017. Economic impacts of invasive alien species on African smallholder livelihoods.39 Biomed Central. 2017. Invasive plant increases malaria transmission.40 BioNET-EAFRINET. Accessed 2018. Parthenium hysterophorus (Parthenium Weed).41 Patel, S. 2011. Harmful and beneficial aspects of Parthenium hysterophorus : an update .

MALAWI WATER RESOURCESThe British Geological Society reports that most of the urban water supply in Malawi comes from groundwater, which is collected from hand-dug wells, springs, and hand-pumped boreholes. According to USAID , approximately 80 percent of the Malawian population has access to an improved source of drinking water, however about 4 million people still lack access to safe water. Only about six percent of Malawi’s population has access to a sanitation facility. Proper sanitation practices and storage of clean drinking water are essential for preventing the spread of waterborne diseases such as cholera. The British Geological Society has stated that the chemical quality of groundwater in Malawi has been little documented, however the main problems affecting groundwaters appear to be high levels of salinity and high fluoride concentrations in some areas. For instance, one study has found elevated fluoride concentrations in groundwater around the village of Chande and the Jali area, both in Zomba District.42 In spite of the high proportion of the Malawian population that now has access to clean drinking water, climate variability and change are likely to endanger water, sanitation, and hygiene. Climate shocks such as intense precipitation and flooding can cause serious damage to boreholes and other water supply infrastructure, and these types of extreme weather events are projected to become more frequent in Malawi. For example, in 2015, record rainfall damaged 3,000 boreholes and water supply and treatment infrastructure in Southern Malawi, leading to flooding and cholera outbreaks in Chikwawa district, bordering Blantyre.

42 Anastasia von Hellens. 2013. Groundwater quality of Malawi - fluoride and nitrate of the Zomba-Phalombe plain.

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

SUB-SAHARAN AFRICA EIA PROCEDURESAccording to the Legal and Regulatory Framework Study of the World Bank 43 , environmental impact assessment, or EIA as it is known, is a procedure for evaluating the impact proposed activities may have on the environment. In recent years, significant strides have been made to build a legal foundation for EIAs in Sub-Saharan Africa. Whereas EIAs typically used to be carried out only to meet requirements of foreign donors, they are now mandated in twenty-two Sub-Saharan countries, as an important element of domestic environmental law and policy. IPs for Madagascar and Malawi are expected to understand and document their compliance with local EIA regulations in their sSupplemental IEEs.

MADAGASCAR REGULATORY STRUCTUREThe goal of sustainable development underlies all of Madagascar’s environmental policy and legal documents, including the country’s constitution, which states, “Everyone shall have the duty to protect the environment; the State shall ensure its protection.”44 In 2010, Madagascar created the Directorate of Climate Change under the Ministry of Environment and Forests (Ministère de l’Environnement, de l’Ecologie et des Forêts), which is responsible for coordinating nationwide adaptation and mitigation measures to combat climate change. There have also been numerous working groups and committees that assist the national government with addressing climate change issues. The Thematic Climate Change Group, formed in 2009, supports the government in drafting climate-related policies and frameworks. In addition, the Health and Climate Working Group is strengthening Madagascar’s capability to integrate climate data in the public health domain.45 The country is also a member on several international agreements, treaties and conventions such as: Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), United Nations Framework Convention on Climate Change (UNFCCC), and Ramsar Convention on Wetlands of International Importance, just to name a few. More detailed information can be found in the FAA 118/119 for Madagascar.

Law No. 90-033 (Loi n° 90-033 sur la charte de l’environnement Malagasy) of 21 December 1990, amended by Law No. 97-012 (Loi n° 97-012) of 6 June 1997 and Law No. 2004-015 (Loi n° 2004-015) of 19 August 2004, provides the Environmental Charter of Madagascar and promulgates the National Environmental Action Plan (NEAP). The NEAP was implemented in three distinct phases known as EP1 (1992-

43 See Madagascar Section on Page 59 and Malawi “Box” on page 2744 USAID. 2017. Madagascar IEE.45 Grantham Research Institute on Climate Change and the Environment. Accessed 2018. Climate Change Legislation in Madagascar.

1996), EP2 (1997-2003), and EP3 (2003-2007). During EP1, the country focused on establishing institutions for the environment (e.g., L’Office National pour l’Environnement, le Ministère de l’Environnement, de l’Ecologie et des Forêts), while activities during EP2 centered on development of approaches and tools for sustainable environmental management. EP3 had seven goals: (1) development of sustainable activities, (2) sustainable management for forest ecosystems and water resources, (3) establishment of protected areas and conservation of sensitive ecosystems, (4) sustainable management for coastal and marine ecosystems, (5) improvement in general behavior about the environment, (6) establishment of sustainable financing for the management of natural resources, and (7) development of better environmental policies and governance.46

In March 2015, Madagascar launched a new National Adaptation Plan development initiative to support policymakers in creating a nationwide strategy for preparing for and responding to the effects of climate change.47 In addition, the Third National Communication of Madagascar on Climate Change to the UNFCCC, released in October 2017, highlights climate mitigation commitments of the country and sector specific climate risks and adaptation measures.

MALAWI REGULATORY STRUCTUREMalawi implements a sectoral approach to conservation of biodiversity, rather than enacting a comprehensive structural and legal framework. The country adopted a National Environmental Policy in 1996 (amended in 2004), derived from the Constitution of Malawi that states the country’s national policy, “To manage the environment responsibly in order to: i) prevent the degradation of the environment; ii) provide a healthy living and working environment for the people of Malawi; iii) accord full recognition to the rights of future generations by means of environmental protection; and iv) conserve and enhance the biological diversity of Malawi.”48 The National Environmental Policy outlines Malawi’s cross-sectoral approach, as well as the requirement that all national and local plans integrate environmental concerns. The Environmental Management Act (1996) is the legislative instrument to implement national environmental policy, and establishes general principles for environmental planning at both the national and district levels. However, effective implementation of either the National Environmental Policy or the Environmental Management Act is uncommon.

The National Land Policy (2002) is another key piece of legislation that guides land use and environmental resource management in Malawi. The law includes ten objectives for environmental management, including protection of sensitive ecosystems, agricultural resource conservation, management of community forests and woodlands, and reforestation programs.49 Other relevant policies governing 46 Managing for Development Results. Accessed 2018. Madagascar: National Environmental Action Plan.47 UNDP. 2015. Madagascar launch NAP to adapt to the effects of climate change.48 Government of Malawi. 2004. National Environmental Policy.49 Government of Malawi. 2002. Malawi National Land Policy.

forests include the National Forestry Policy (1996) and the Forestry Act (1997), which include provisions about forest management and sustainable use of forest resources.

Aquaculture is a strategic resource for Malawi, which has several statutes governing water and fisheries management including the National Fisheries and Aquaculture Policy (2001), Fisheries Conservation and Management Act (1997), National Water Policy (1994) and Water Resources Act (1969). These laws collectively address protection of fish and fishing communities, management of water resources (including provision of potable water), and operation of aquaculture.

Malawi has acceded to various international environmental treaties, conventions, and protocols, including the UNFCCC, CITES, Ramsar, and the Convention to Combat Desertification, among others. However, an assessment of the Ministry of Natural Resources, Energy and Environment, which is responsible for implementing cross-sectoral environmental programs, revealed that many of Malawi’s aforementioned domestic policies and legislation are not enforced in practice. Issues with duplicative and overlapping functions among different ministries and lack of coordination contribute to weak enforcement of environmental legal frameworks. For instance, both forestry and water management legislation have mandates over water resources in forested areas. More detailed information can be found in the FAA 118/119 for Malawi.

To limit the impacts of climate change to Malawi, the country developed a National Adaptation Programme of Action in 2006. Malawi released their First National Communication on Climate Change to the UNFCCC in 2003 and their Second National Communication on Climate Change in 2012. These documents guide climate change mitigation commitments from the country, and highlight climate change adaptation needs.

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

3.1 ENVIRONMENTAL IMPACTS OF COMMODITY FUMIGATIONMost FFP activities will carry out the storage and protection of commodities, either as US in-kind food assistance or as locally-procured food commodity. To prevent the loss of food commodity from pest infestations during storage, it is common practice to perform periodic fumigation of warehouses and/or the application of contact pesticides to warehouse surfaces.

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

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

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

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

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

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

● Phosphine may not completely control fungal contamination.

In addition, it is a USAID agency commitment that activities consider the procurement or promotion of pesticides as a last resort within an Integrated Pest Management (IPM) framework (see USAID Special Topic Presentation on Pesticides). Whichever their intended use may be, pesticides are potent killing agents and their

use poses intrinsic dangers to applicators, households, communities and the environment. These risks include, but are not limited to:

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

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

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

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

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

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

Potential environmental and social impacts

Potential climate risks

Warehouse treatment of bagged and bulk commodity

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

● Negative health impacts of residents near fumigation sites

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

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

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

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

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

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

3.2 CLIMATE RISKS TO COMMODITY FUMIGATION As noted in Section 2, Madagascar and Malawi will both experience increasing temperatures. Malawi will likely see an increase in frequency and intensity of heavy rainfall events, leading to increased flooding, particularly in the south. There are also likely to be more drought events. Madagascar will likely experience overall decrease in precipitation, increase intensity of cyclones, and coastal areas will suffer from sea level rise. The climate changes expected in Madagascar and Malawi could impact fumigation by, changing herbivore and pathogen range and occurrence, which should also be considered during fumigation, and threatening the effectiveness of fumigation storage effectiveness.

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

4.0 ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATING 4.1 RECOMMENDED ENVIRONMENTAL DETERMINATIONS50

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

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

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

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

TABLE 3: ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGSIllustrative

Interventions22 CFR 216

Environmental Determination

Climate Risk Rating

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

Other FFP Program Areas and Elements Deferral Deferral

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

5.0 CONDITIONS AND MITIGATION MEASURES5.1 CONDITIONSFor applicants, USAID FFP environmental compliance at the time of activity design will be met through adherence to both 1) this RFA IEE and 2) completion of a stand-alone, Supplemental IEE, only upon USAID’s indication of an intent to award. Once the Supplemental IEE, including the Environmental Mitigation and Monitoring Plan (EMMP), CRM screening, and IAP (including attendant budget), is finalized and approved by the DCHA BEO, the IEE is to be used to guide activity implementation. All mitigation measures contained in the Supplemental IEE must be implemented and monitored for effectiveness in reducing potential environmental impacts resulting from interventions.

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

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

Figure 3. Overarching Environmental Compliance Flowchart for FFP Activities

5.1.1 PRE-AWARD STAGECONDITION 1: APPLICANT TO SUBMIT ENVIRONMENTAL SAFEGUARDS PLAN.USAID requires analyses which consider environmental risks across the Agency, using a set of defined procedures to meet USAID environmental requirements. Applicants are expected to design innovative approaches to promote environmental

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

This plan must summarize:

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

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

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

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

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

Upon receipt of the FFP award, implementing partners will be required to develop a Supplemental IEE51, specific to the award. The Supplemental IEE will describe the environmental impact analysis for all interventions in the project’s zone of influence, within the FFP geographies described in the RFA . In short, the Supplemental IEE must 1) summarize the technical design, 2) describe baseline environmental conditions in the FFP zones of influence 3) identify all reasonably foreseeable environmental impacts of interventions, and 4) recommend sound mitigation measures to prevent, reduce or compensate for environmental impacts.

Timing: As described in Table 4, awardees must submit a draft of the Supplemental IEE (including EMMP, CRM, and IAP components) no later than 14 weeks after the post-award conference. This timing is tied to the post-award conference but aligns with the timing of the M&E workshop. Awardees must submit the final Supplemental IEE to USAID no later than eight weeks after the R&I Culmination Workshop for official approval. As desired, awardees can submit revised versions of the Supplemental IEE to USAID for informal review between the draft and final versions.

51 A word versions of the Supplemental IEE template can be found at a Google drive here: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8

Refine and Implement: FFP has been awarding its development food security activities under a collaborative model known as Refine and Implement (R&I). FFP plays a partnership role through substantial involvement in the R&I process. Intended to improve activity design, fit to context and implementation planning, R&I includes two stages: the refinement period, which lasts for approximately the first year, and the implementation period during years 2-5. The Key Collaboration Events detailed in Table 4 occur during the one-year refinement period.

TABLE 4. REFINEMENT PERIOD OF REFINE AND IMPLEMENT FOR MALAWI AND MADAGASCAR – KEY COLLABORATION EVENTS52 WITH RELEVANT IEE ACTIONS.

Key Collaboration Event

Timing IEE Action

Post-Award Conferences (DC)

Immediately after award

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

● Awardee submits draft Supplemental IEE to USAID no later than 14 weeks after post-award conference

Kickoff Meetings(In Country)

Within weeks of award after discussion and agreement with IPs

● FFP field present the RFA IEE Conditions to awardee

Gender Consultation(In Country)

Approximately ten weeks after award

● N/A

M&E / R&I Inception workshop(In Country)

Approximately 14 weeks after award

● Option 1: BEO office presents environmental and CRM compliance process

● Awardee refines Supplemental IEE as needed (option to submit to USAID for informal review)

Baseline Workshop(In Country)

Approximately 16 weeks after award

● Option 2: BEO office presents environmental and CRM compliance process

● Awardee refines Supplemental IEE as needed (option to submit to USAID for informal review)

R&I Culmination Workshop(In Country)

Approximately 12-14 months after award

● Awardee submits final Supplemental IEE to USAID no later than eight weeks after R&I Culmination Workshop (for official approval)

52 As described in the FY19 Madagascar and Malawi RFA FY 19 Madagascar and Malawi RFA IEE

Chief of Party Presentations(In Country)

Approximately 13-15 months after award

● Awardee presents budgeting and staffing for environmental monitoring of the IEE

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

● For a general introduction on how to develop an IEE, consult the USAID IEE Assistant.53

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

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

IEE AmendmentsIEE Amendments: In the event that any new proposed interventions differ substantially from the type and/or agroecological zone of interventions described in the Supplemental IEE, an IEE Amendment (IEE-A) will be developed, including a revised EMMP (and potentially revised IAP and CRM screening, as needed). Amendments must be sent to FFP and reviewed for approval by the DCHA/BEO prior to implementation.

Some of the possible triggers for an IEE-A include, but are not limited to: modified or new interventions, new geographic zone, cost extension, and/or significant time extension, such as an additional year..Pursuant to 22 CFR 216.2(b), activities involving international disaster assistance or other emergency circumstances may be Exempt from these procedures. Emergency activities with Agreement Officer approval may be Exempt from environmental review, such as the transfer of food commodities pursuant to 22 CFR 211.

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

53 Provides useful overall process information, but templates are out of date and should not be used. FY 19 Madagascar and Malawi RFA IEE

As a component of the Supplemental IEE, FFP applicants must complete an EMMP54 which serves as the implementation and monitoring plan for all required 22 CFR 216 compliance actions to be taken by a given activity. This RFA IEE provides a template for the EMMP in the annexes. Detailed guidance and best-practice considerations for the development of the EMMP is available on the USAID Environmental Procedures Website55 and in the Environmental Mitigation and Monitoring Plan Factsheet. The effectiveness of the individual compliance actions (mitigation measures) to prevent or reduce environmental impacts must be monitored periodically throughout the life of the activity. The results of this monitoring should be described in the annual ESR. See information below.

CRM ScreeningAs a component of the Supplemental IEE, upon receipt of the award, the partners will develop a Climate Risk Management (CRM) screening for all activities. CRM is the process of assessing, addressing, and adaptively managing climate risks that may impact the ability of USAID programs to achieve their objectives. It is recommended that Climate Risk Management screening begin with the Supplemental IEEs under this RFA, with the exception of fumigation activities (See Annexes 5 & 6 for more details). Currently, the activity interventions for this RFA are not well defined in scope or technical approach, and therefore it is appropriate to begin Climate Risk Management screening when they are better defined, at the Supplemental IEE stage, pursuant to Climate Risk Management for Projects and Activities. A Mandatory Reference for ADS 201. It is likely that many of these interventions will have high and moderate climate risks during implementation. When high and moderate climate risks are identified, Climate Risk Management screening for these activities must be resolved in the post-award Supplemental IEE, in which climate risks, and opportunities to integrate climate into programming, will be identified and addressed as outlined by USAID policy and FFP Climate Risk Management guidance (found in Annex 5 and also on the Climatelinks Climate Risk Management website). Furthermore, Climate Risk Profiles identify Climate Risks in Food for Peace Geographies and for Madagascar and Malawi have been developed to assist with CRM screening under this RFA-IEE:

● Climate Risks in Food for Peace Geographies - Madagascar

● Climate Risks in Food for Peace Geographies - Malawi

IAPAs a component of the Supplemental IEE, the Institutional Arrangement Plan (IAP)56, is a useful tool to help frame the budget and staffing needs for IEE implementation.

54 A word versions of the EMMP template can be found at a Google drive here: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS855 This website is under construction, and will be available soon.56 A word versions of the IAP template can be found at a Google drive here: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8

This is not a new requirement, but rather a new framing for an existing need. The IAP describes the implementing partner capacity for fulfilling the implementation conditions required by the Supplemental IEE, EMMP and CRM screening. The IAP is submitted with the Supplemental IEE, and is later updated with the annual ESR57. A budget for the implementation of the IEE (which is attached to the IAP) must be transparently demonstrated in the Detailed and Comprehensive Budget and Budget Narrative for the award. The budget includes provisions for:

● internal staffing

● technical support

● training

● monitoring/reporting

● pesticide expertise

● environmental assessments, as needed

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

Budget Guidance. The budget for environmental compliance must not exceed the Total Estimated Cost (TEC) of the multi-year activity. Rather this compliance budget must be allocated from within the award TEC. Failure to do so in a transparent manner, will result in delays. The budgeting for environmental compliance is to be reviewed in the beginning of the activity, and annually with the Pipeline and Resource Estimate Proposals (PREPs58). Refer to the USAID Environmental Budgeting Toolkit for step-by-step guidance for both budget developers and USAID budget reviewers. While the BEO can provide guidance on budgeting for environmental compliance, only the AOR can authorize budget commitments.

57 *The ESR is similar to the Environmental Mitigation and Monitoring Report (EMMR) used elsewhere in USAID. However, the ESR meets both purposes of reporting and budget planning for environmental compliance.58 The PREP describes an awardee's resource needs and interventions for a specific upcoming period of time agreed to by the partner and the Agreement Officer’s Representative.

Figure 4 Developing Activity Budgets for Environmental Compliance Requirements.Source: Adapted From Environmental Compliance Budgeting Toolkit, P. 5.

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

The BEO Issues LetterAfter reviewing IP inputs, both post-award and throughout the project life-cycle (IEEs, ESRs, PERSUAPs, EAs, etc.), the BEO will prepare an “Issues Letter” highlighting questions, concerns, or changes that should be made to the document before it can receive final BEO clearance. IPs will need to respond to the Issues Letter and revise their documentation accordingly before re-submitting for BEO clearance. Upon final BEO and CIL approval, all environmental compliance documentation is subsequently shared with the implementing partner and uploaded to the publicly accessible Environmental Compliance Database. Supplemental IEEs must be approved by the USAID DCHA Bureau Environmental Officer (BEO) and Climate Integration Lead (CIL) prior to the implementation of medium-risk interventions (i.e., classified as a Negative Determination with Conditions as per 22 CFR 216).

CONDITION 3: IMPLEMENT ENVIRONMENTAL MONITORING REQUIREMENTSEnvironmental monitoring is crucial to ensuring that environmental compliance and climate risk management requirements are being successfully implemented. Partners can use environmental monitoring systems and site visits (described below) to implement monitoring requirements. These methods should be incorporated into the project’s wider M&E systems.

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

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

Drinking Water Quality-- Requirements and Additional Guidance

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

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

significant environmental design and management considerations by development sector.

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

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

USAID Environmental Compliance Site Visits: As required by ADS 204.5.4, the AOR, in consultation with FFP Managers, Mission Environmental Officers (MEO) and/or the DCHA/BEO will actively monitor and evaluate whether environmental consequences unforeseen under interventions covered by this current RFA IEE, and the Supplemental IEEs, arise during implementation and modify or end interventions as appropriate.

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

The M&E workshops, held at the start-up of new FFP development food security activities, are designed to convey M&E requirements and to strengthen awardees’ Logical Frameworks and Indicator Performance Tracking Tables (IPTTs). During these workshops, awardees have an opportunity to learn about environmental considerations with M&E experts to coordinate the IPTT with the EMMP.

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

As described in the Policy and Guidance for Monitoring, Evaluation, and Reporting of Development Food Security Activities, awardees may make other additions to the Performance Indicator Reference Sheet (PIRS) to clarify the use of a FFP or Mission indicator in the activity’s M&E Plan. For example, text may be added to the Rationale section to identify the indicator as part of the activity’s EMMP and explain how the indicator is environmentally sensitive to the activity context (please see the Recommended Performance Indicator Reference Sheet). Clarifications inserted into the PIRSs, like those described above, do not ‘change’ the FFP or Mission indicator; they simply add more information about how the indicator will be collected and which activities beneficiaries or outputs will be considered.

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

Environmental Status Report (ESR)

ESRs59 must be completed by all FFP awardees on an annual basis to report on progress toward achieving environmental compliance. ESRs must be submitted along with the M&E plans in January, or at least three 1-3 months before the anticipated PREP submission by the partners. The ESR is designed to:

1. Document environmental safeguard staffing and budget for the upcoming implementation year, matching the budget narrative for the award; and

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

The ESR Guidance (see template60 in Annex 4 and guidance on the overall process here) provides instruction to awardees on what information must be included in the

59 Also known as Environmental Mitigation and Monitoring Reports (EMMRs) elsewhere in USAID.60 A word version of the ESR template can also be found at the following Google Site: and at the following Google Drive: https://drive.google.com/drive/u/1/folders/1CwBSuhORG54Ehe94KbpdeciIwO52zGS8

Mission Requirements for Sub-project Review The Environmental Review Form (ERF) and Environmental Review Report (ERR) * were developed by the USAID Africa Bureau to enhance environmental management and oversight of USAID programming for sub-projects that may not be well-defined at the IEE stage. As noted in the ERF/ERR Form and Instructions, the BEO will not clear an IEE or EA that authorizes use of the ERF unless ALL of the following are true:

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

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

Annual Results Reports (ARRs)

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

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

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

● Programs of river basin development;

● Irrigation or water management projects, including dams and impoundments;

● Agricultural land leveling;

● Drainage projects;

● Large scale agricultural mechanization;

● New lands development;

● Resettlement projects;

● Penetration road building or road improvement projects;

Mission Requirements for Sub-project Review The Environmental Review Form (ERF) and Environmental Review Report (ERR) * were developed by the USAID Africa Bureau to enhance environmental management and oversight of USAID programming for sub-projects that may not be well-defined at the IEE stage. As noted in the ERF/ERR Form and Instructions, the BEO will not clear an IEE or EA that authorizes use of the ERF unless ALL of the following are true:

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

● Powerplants;

● Industrial plants;

● Potable water and sewerage projects other than those that are small-scale.

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

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

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

Tiering off of Existing Mission PERSUAPs. As soon as interventions in which the procurement or promotion of pesticides is anticipated, it is recommended that awardees contact their Mission Environmental Officer (MEO) to inquire whether an existing PERSUAP has been developed in the country or region that provides the requisite approval and guidance for the use of a particular pesticide or series of pesticides61. FFP encourages its awardees to tier off existing USAID analyses when possible, thereby reducing the need to carry out new and potentially redundant analyses, yet allowing for the appropriate consideration of the specific needs and context of each development food security activities. In this case, the FFP activity will need to develop a Safe Use Action Plan (SUAP). The SUAP provides a succinct, definitive stand-alone statement of compliance requirements, synthesized from the 12-factor analysis. It also assigns responsibilities and timelines for implementation of these requirements.

6B. COMMODITY FUMIGATION MITIGATION REQUIREMENTS, PER THE USAID PEA FOR PHOSPHINE FUMIGATION OF STORED AGRICULTURAL COMMODITYUSAID requires that the person/people carrying out commodity fumigation operations hold official certification to perform the fumigation, use fumigants

61 For Malawi, see the USAID/Malawi Mission-wide PERSUAP. For Madagascar, see the FFP ADRA & CRS PERSUAP.

according to the directions on the product label, and follow all listed directions, precautions, and restrictions. Fumigants will be used only for commodities and at sites specified by the product label.

USAID has developed an assessment of environmental and health risks in the fumigation of food assistance commodity entitled USAID Programmatic Environmental Assessment (PEA) for Phosphine Fumigation of Stored Agricultural Commodity. The PEA includes a Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) template, and a Fumigation Management Plan (FMP) template. These tools are intended to assist in compliance with the Fumigation PEA’s requirement for completion of an activity-specific PERSUAP and FMP reporting. The Fumigation PERSUAP should be developed as soon as the warehouse and fumigation service providers are identified, and in advance of the need for fumigation. It is preferred that this PERSUAP be submitted with the Supplemental IEE, if possible. Specific mitigation requirements for the fumigant phosphine are provided in the Fumigation PEA.

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

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

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

CONDITION 8: ENSURE COMPLIANCE WITH PARTNER COUNTRY ENVIRONMENTAL REGULATIONSImplementation will in all cases adhere to applicable partner country environmental laws. The Supplemental IEE supports and strengthens the rule of law for systems of environmental governance in partner countries. In order to ensure environmental compliance, the status and applicability of the partner country’s policies, programs, and procedures in addressing natural resources, environment, food security, and other related issues must be incorporated into each activity. This may include incorporating the national policies pertaining to environmental assessment or other policies related to the sector. Implementing partners must be aware of and ensure compliance with the country’s regulations where their activity is located.

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

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

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

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

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

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

● Provide support to extractive industries (e.g. mining and quarrying) per FAA 117;

● Promote timber harvesting per FAA 117 and 118;

● Lead to new construction, reconstruction, rehabilitation, or renovation work per §216.2(b)(1);

● Support agro-processing or industrial enterprises per §216.1(b)(4);

● Provide support for regulatory permitting per §216.1(b)(2);

● Lead to privatization of industrial facilities or infrastructure with heavily polluted property per §216.1(b)(4);

● Procure or use genetically engineered organisms per §216.1(b)(1); and/or

● Assist the procurement (including payment in kind, donations, guarantees of credit) or use (including handling, transport, fuel for transport, storage, mixing, loading, application, clean-up of spray equipment, and disposal) of pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials. Pesticides cover all insecticides, fungicides,

rodenticides, etc., covered under the Federal Insecticide, Fungicide, and Rodenticide Act per §216.2(e) and §216.3(b).

7.0 REVISIONSPer 22 CFR 216.3(a)(9), when ongoing programs are revised to incorporate a change in scope or nature, a determination will be made as to whether such change may have an environmental impact not previously assessed. If so, this IEE will be amended to cover the changes. Per ADS 204, it is the responsibility of the USAID AOR to keep the relevant MEO, REA and BEO (Erika Clesceri) informed of any new information or changes in the activity that might require revision of this environmental analysis and environmental determination.

ATTACHMENTS62:ANNEX 1: TEMPLATE FOR SUPPLEMENTAL INITIAL ENVIRONMENTAL EXAMINATIONS

ANNEX 2: TEMPLATE FOR ENVIRONMENTAL MITIGATION AND MONITORING PLANS

ANNEX 3: TEMPLATE FOR INSTITUTIONAL ARRANGEMENT PLAN

ANNEX 4: TEMPLATE FOR ENVIRONMENTAL STATUS REPORTS

ANNEX 5: GUIDANCE FOR CLIMATE RISK MANAGEMENT SCREENING

ANNEX 6: CLIMATE RISK MANAGEMENT SCREENING TABLE FOR FUMIGATION

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

ANNEX 1: TEMPLATE FOR SUPPLEMENTAL INITIAL ENVIRONMENTAL EXAMINATIONS

INITIAL ENVIRONMENTAL EXAMINATIONACTIVITY DATAActivity Name:Amendment (Y/N):Geographic Location(s) (Country/Region):Implementation Start/End:Solicitation/Contract/Award Number:Implementing Partner(s):Link of Other, Related Analyses: Parent IEE: FY 19 RFA IEE

ORGANIZATIONAL/ADMINISTRATIVE DATAImplementing Operating Unit(s): (e.g. Mission or Bureau or Office)Funding Operating Unit(s): (e.g. Mission or Bureau or Office)Funding Account(s):Funding Amount:Amendment Funding Date: Amendment Funding Amount:Other Affected Unit(s):Lead BEO Bureau:Prepared by:Date Prepared:

ENVIRONMENTAL COMPLIANCE REVIEW DATAAnalysis Type: ☐ Initial Environmental Examination

☐ AmendmentEnvironmental Determination(s): ☐ Categorical Exclusion

☐ Negative Determination☐ Positive Determination☐ Deferral

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

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

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

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

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

IMPLEMENTATIONIn accordance with 22 CFR 216 and Agency policy, the conditions and requirements of this document become mandatory upon approval. This includes the relevant limitations, conditions and requirements in this document as stated in Sections 3, 4, and 5 of the IEE and any BEO Specified Conditions of Approval.

USAID APPROVAL OF INITIAL ENVIRONMENTAL EXAMINATIONACTIVITY NAME:

Approval: __________________________________________________Mission Director

_____________Date

Clearance: __________________________________________________Food for Peace Officer (FFPO)*

______________Date

Clearance: __________________________________________________Mission Environmental Officer (MEO)

______________Date

Clearance: __________________________________________________Agreement Officer’s Representative (AOR)

______________Date

Clearance: __________________________________________________Agreement Officer (AO)

______________Date

Clearance: __________________________________________________Regional Environmental Advisor (REA)*

______________Date

Clearance: __________________________________________________Kyle Rearick, Climate Integration Lead (CIL)

______________Date

Concurrence:

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

______________Date

*Clearance recommended, but optional.

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

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

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

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

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

TABLE 1: DEFINED INTERVENTIONS[Intervention 1 — Title]

[Intervention 2 — Title][Intervention 3 — Title][Intervention 4 — Title][Intervention 5 — Title][Intervention 6 — Title][Intervention 7 — Title][Add rows as needed]

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

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

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

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

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

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

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

[Intervention Title]Potential environmental and social impacts

[Description of Intervention]

[Add rows as needed]

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

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

[Intervention Title]Potential environmental and social impacts

[Description of

Intervention]

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

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

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

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

TABLE 3: ENVIRONMENTAL DETERMINATIONS AND CLIMATE RISK RATINGS

Interventions

Categorical Exclusion Citation (if applicable)

Negative Determination

Positive Determination

Deferral

Climate Risk Rating

[Intervention 1 Title]

4.2 CLIMATE RISK MANAGEMENT[INSTRUCTIONS (TO BE DELETED ONCE COMPLETED): In accordance with Agency policy, include a brief narrative of the risk assessment methodology and refer to the the Climate Risk Management Summary Table which should be attached as an annex(table below or table from Climate Risk Screening and Management Tool). Refer to ADS 201mal “Climate Risk Management for USAID Projects and Activities.”]

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

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

[INTERVENTION 1 TITLE]

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

[Intervention Title] Mitigation Measures[Description of Intervention]

[INTERVENTION 2 TITLE]

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

[Intervention Title] Mitigation Measures[Description of Intervention]

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

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

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

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

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

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

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

● Provide support to extractive industries (e.g. mining and quarrying) per FAA 117;

● Promote timber harvesting per FAA 117 and 118;

● Lead to new construction, reconstruction, rehabilitation, or renovation work per §216.2(b)(1);

● Support agro-processing or industrial enterprises per §216.1(b)(4);

● Provide support for regulatory permitting per §216.1(b)(2);

● Lead to privatization of industrial facilities or infrastructure with heavily polluted property per §216.1(b)(4);

● Procure or use genetically engineered organisms per §216.1(b)(1); and/or

● Assist the procurement (including payment in kind, donations, guarantees of credit) or use (including handling, transport, fuel for transport, storage, mixing, loading, application, clean-up of spray equipment, and disposal) of

pesticides or activities involving procurement, transport, use, storage, or disposal of toxic materials. Pesticides cover all insecticides, fungicides, rodenticides, etc. covered under the Federal Insecticide, Fungicide, and Rodenticide Act per §216.2(e) and §216.3(b).

7.0 REVISIONSPer 22 CFR 216.3(a)(9), when ongoing programs are revised to incorporate a change in scope or nature, a determination will be made as to whether such change may have an environmental impact not previously assessed. If so, this IEE will be amended to cover the changes. Per ADS 204, it is the responsibility of the USAID AOR and awardees to keep the MEO/REA and BEO informed of any new information or changes in the activity that might require revision of this environmental analysis and environmental determination.

ATTACHMENTS:ENVIRONMENTAL MITIGATION AND MONITORING PLAN

INSTITUTIONAL ARRANGEMENT PLAN

CLIMATE RISK MANAGEMENT SUMMARY TABLE

BEO ISSUES LETTER

REFERENCE DOCUMENTS

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

Interventions Identified Environmental Aspects or Impacts

Mitigation Measure(s)

Monitoring Indicator(s)

Monitoring and Reporting Frequency/ Methods

Responsible Parties

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

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

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

TIMING: IAP submitted Initially with IEE, and then updated with the ESR63.

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

1. Narrative: Description of the institutional and individual responsibilities, per the four (4) following elements:

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

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

c. How the monitoring data is operationalized for improving sound environmental performance and climate risk management;

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

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

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

conceptualize the responsibilities and relationships between the institutions responsible for implementing environmental compliance and CRM requirements.

3. Attachment: IEE Budget and Budget Narrative.

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

INSTITUTIONAL ARRANGEMENT PLAN FOR PROGRAM XYZDESCRIPTION

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

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

TABLE 1. ROLES AND RESPONSIBILITIES FOR IMPLEMENTING ENVIRONMENTAL MANAGEMENT SYSTEM

INSTITUTION INDIVIDUAL RESPONSIBILITIES / CAPACITY

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

FIGURE 1. ORGANIZATIONAL CHART

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

ATTACHMENT: IEE BUDGET NARRATIVE AND BUDGET

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

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

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

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

ANNEX 4: TEMPLATE FOR ENVIRONMENTAL STATUS REPORTS

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

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

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

PURPOSE AND SCOPEEnvironmental Status Reports (ESRs64) are required for USAID-funded activities when the 22 CFR 216 documentation governing the activity imposes conditions on at least one of the activity’s interventions. ESRs ensure that the ADS 204 requirements for reporting on environmental compliance are met.

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

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

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

USAID APPROVAL OF ENVIRONMENTAL STATUS REPORTACTIVITY NAME:

Clearance:

______________________________________

Mission Environmental Officer (MEO)

___________________

Clearance:

______________________________________

Food For Peace Officer (FFPO)*

___________________

Clearance:

______________________________________

Regional Environmental Officer (REO)*

___________________

Clearance:

______________________________________

Agreement Officer’s Representative (AOR)

___________________

Concurrence:

______________________________________

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

___________________

DISTRIBUTION: DCHA Climate Integration Lead (CIL); Regional Bureau Environmental Officer (BEO)

*Clearance recommended, but optional.

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

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

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

INSTITUTIONAL ARRANGEMENT PLAN UPDATE

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

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

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

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

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

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

B. EMMP MONITORING[Topic 6: Provide a brief narrative on progress implementing the EMMP (see EMMP Monitoring Table in Section 4). Include description of the EMMP environmental monitoring systems. Include staff or beneficiary trainings conducted, photos of mitigation measures and activities, etc.]

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

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

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

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

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

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

Interventions

EMMP Mitigation Measures

(Indicate any additions or deletions)

EMMP Indicators

(Indicate any additions or deletions)

Results Remarks and Description of Necessary Corrective Actions

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

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

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

TABLE 1. CLIMATE RISK MANAGEMENT SUMMARY TABLE

Defined or Anticipated Activity Interventions

Timeframe

Geography

Climate Risks

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

Risk Rating

Low/Moderate/ High

Climate Risk Management Options

How are risks addressed

Opportunities to Strengthen Climate Resilience

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

Table + Narrative: In addition to the CRM Table, the ADS Guidance requires a “summary of the approach to activity-level CRM and major results”. This should briefly clarify how risks were identified and assessed, and also include critical resources referenced. If there are opportunities to reduce greenhouse gas (GHG) emissions associated with implementing the activity, describe them in the narrative.

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

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

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

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

TABLE 2. CLIMATE RISK RATINGS

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

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

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

CLIMATE RISKSCONSTRUCTION MANAGEMENT MEASURES

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

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

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

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

access to and use of commodities-Determine if alternative water sources are available and develop plans for accessing them if necessary

ANNEX 6: CLIMATE RISK MANAGEMENT SUMMARY TABLEDefined or Anticipated Program Intervention

Timeframe

Geography Climate Risks

Risk Rating

Climate Risk Management Options

How are risks addressed

Opportunities to Strengthen Climate Resilience

Commodity Fumigation

Life of the award, until 2023.

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

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

Low Educate applicators on importance of wearing protective equipment.

Educate applicators on importance of wearing protective equipment.

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

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

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

Ask local community members about

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

Ask local community members about observed changes in pathogen and pests

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

Consider climate change impacts when planning inspection

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

over recent years and use fumigation that is relevant for the current situation.

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

times to ensure that any new pest species or increasing occurrences of pest infestations are identified as early as possible.

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

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

Ensure that all pesticides stored in warehouses (as non-fumigants may also be stored in warehouses) are in locations safe from the impacts of extreme

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

Ensure that all pesticides stored in warehouses (as non-fumigants may also be stored in warehouses) are in locations safe from the impacts of extreme weather events (i.e., on

During the site selection process, raise awareness of the risks to warehouses and commodities of exposure to extreme weather or regular flooding, or sea level rise in Madagascar.

Improve early warning of climate and weather events, such as rainfall or flood, to improve preventative protection of commodities and stored pesticides.

weather events (i.e., on raised platforms in the case of flood risk).

raised platforms in the case of flood risk).

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