INITIAL ENVIRONMENTAL EXAMINATION (IEE)Amendment#2 to Asia 15-078 Indonesia IEE PIO Grant to UNOPS for GAMBUT

PROGRAM/ACTIVITY DATA

Development Objective (DO) Development Objective (DO) 3 – Global Development Priorities of Mutual Interest Advanced

Country Indonesia

Project Title

Public International Organization Grant to United Nations Office for Project Services (UNOPS) for GAMBUT (Generating Anticipatory Measures for Better Utilization of Tropical Peatlands) Project

Life of Program (LOP) Duration July 1, 2015 – December 31, 2018LOP Funding $3,945,530Current Date May 16, 2018

IEE Prepared by: Yusak Oppusunggu (ENV-USAID/Indonesia)

IEE Amendment (Y/N): YIf ‘YES’, Number and Date of Original IEE: Original : Asia 15-078 dated June 10, 2015 (https://ecd.usaid.gov/repository/pdf/43896.pdf)Amendment#1: Asia 18-003 date July 31, 2017 (https://ecd.usaid.gov/repository/pdf/50512.pdf)     ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)Categorical Exclusion:   [X]    Negative Determination with Conditions: [X]   Positive Determination: [   ]    Deferral:                                      [   ]

ADDITIONAL ELEMENTS: (Place X where applicable)Conditions: [X]

SUMMARY OF FINDINGS:

A Categorical Exclusion is recommended pursuant to 22 CFR 216.2(c)(2)(i) for education, technical assistance, or training programs; 22 CFR 216.2(c)(2)(iii) for analyses, studies, academic or research workshops and meeting activities; 22 CFR 216.2(c)(2)(v) for documents and information transfers; and 22 CFR 216.2(c)(2)(xiv) for studies and activities intended to build the capacity of the recipient country to engage in development planning.

A Negative Determination with Conditions is recommended in accordance with 22 CFR 216.3(a)(2)(i) for GAMBUT Project activities involving actions that directly or indirectly affect the physical or natural environment, including spatial and land-use planning, small-scale construction activities designed to assist communities with peat fire prevention, such as interventions used to reroute, control, and collect water; assistance in agricultural practices such as small scale irrigation systems; alternative crops or cropping patterns; or modified land use patterns; and, peat forest or agricultural land rehabilitation and reforestation.

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UPDATE USAID/Indonesia and United Nations Office for Project Services (UNOPS) conducted joint monitoring of the GAMBUT Central Kalimantan site on October 26, 2017.  The team met with two Regional Disaster Management Agencies or Badan Penanggulangan Bencana Daerah (BPBDs), in Palangkaraya for Provincial level and in Pulang Pisau for District level, as well as with the Community Working Groups to discuss some progresses and challenges. The team acknowledged the progress of the activities and compliance with the terms outlined in IEE Amendment No. 1. Since this site visit, continual coordination and meetings with UNOPS on GAMBUT activities have taken place, including an April 2018 meeting with UNOPS and the  National Disaster Management Agency (BNPB) Deputy Director to discuss GAMBUT support to the GOI to reduce the risk of forest fires, with a particular focus on the upcoming August 2018 Asian Games in South Sumatra. In August, the Washington-based Agreement Officer's Representative (AOR) for the U.S. Office of Foreign Disaster Assistance (OFDA) will visit the GAMBUT site in Central Kalimantan.  1.  PURPOSE AND SCOPE On September 16, 2015, OFDA/Washington issued the GAMBUT award to UNOPS, with funds from USAID/Indonesia and OFDA.  USAID/Indonesia prepared the original IEE and its following amendments as USAID/Indonesia contributed the initial funds for this award. The original IEE (Asia 15-078 dated June 10, 2015) was valid through December 31, 2016, the initial end date of the award. The purpose of the first IEE amendment (Asia 18-003, dated July 31, 2017) was to correspond with the extension of the project through December 31, 2017, increased the ceiling of the award from $2,084,892 to $3,345,530, and revision of some of the activities under the scope of the project.  The first amendment of the IEE expired on December 31, 2017. Through a letter dated on November 14, 2017, OFDA/Washington extended the award with a no-cost extension from December 31, 2017, to June 30, 2018. According to the Bureau Environmental Officer guidance (see section 6.2 of this IEE), an IEE amendment is not needed if there is an extension for six months or less and the funding level increase is less than $250,000.  However, through the recent Award Modification No. 5, OFDA/Washington extended the award again, this time to December 31, 2018 and increased the total funding by $600,000.  For this reason, at this time USAID/Indonesia has prepared this IEE Amendment No. 2. 

The purpose of this IEE Amendment No. 2 is to: extend the IEE completion date from December 31, 2017 to December 31, 2018; increase the total estimated amount of activities covered under the IEE from $3,345,530 to

$3,945,530; and expand the forest fire reduction activities in two provinces of West Kalimantan and South

Sumatra; add activities in the alternative livelihood that will support the sustainable management of peat environments, and move people away from slash burn practices; and support BNPB (National Disaster Management Agency) aerial firefighting resource scoping

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in the anticipation of the fire season in August in South Sumatra, the location of the Asian Games.

The scope and nature of all other activities as approved in the original IEE (Asia 15-078) remain the same.

2. BACKGROUND AND ACTIVITY DESCRIPTION

2.1 BACKGROUND AND ACTIVITY

The 2014 fire episodes in Riau and in Central Kalimantan underline a long term, dramatic increase in fire vulnerability within the Indonesian peat landscape. In the early 2000s, fire was used mainly as a tool for forest clearance and incidence was most severe during dry years, which were linked to the El Niño Southern Oscillation (ENSO). This resulted, to a significant extent, in similar fire patterns for Central Kalimantan and Riau, where fires would escalate during an El Niño year, with normal and La Niña years remaining relatively fire free. However, the recent 2013, 2014 and early 2015 fire outbreaks in Riau demonstrated a clear break from this pattern and instead show new areas of rapidly increasing fire vulnerability. Research has since shown that during the last five years or so, fire outbreaks have been observed after a relatively short period of below average rainfall in an otherwise wet year in highly localized areas with high intensity; this means that, in Riau, fire risks are higher not only in dry years, but in wet years as well. This is significant due to the importance that Riau province, and the island of Sumatra, has on regional haze and health impacts: the fires of both 2013 and 2014 also resulted in record high air pollution in Singapore.

The underlying causes of the changes in Riau fire dynamics are still being researched. But initial field assessments showed that the emergence of independent smallholder growers in Riau have led to major shifts in land use, supply chains and demographics, fueling increased fire vulnerability. The various pressures on the land have encouraged the development of smallholders, who clear land cheaply through the use of fire. The process of smallholder palm oil development itself is also fueled by changes in palm oil legislation, which have provided the opportunity for the establishment of milling operations without plantations, the provision of feedstock, and the facilitation of independent cultivation by smallholders outside contract farming arrangements. This also occurs alongside the inability and/or unwillingness to control encroachment, especially in production forest areas. Customary land claims by communities are often a first step to claim control over forest lands. After claims are acknowledged at village level, the land is cleared and then sold to migrants or other medium sized entrepreneurs who cultivate palm oil on these lands.

The land is being opened up by smallholders for palm oil development is located on peat land that has to be drained before palm oil or most other crops can be cultivated. This creates high vulnerability to fire, particularly during periods of low rainfall, when draining peat reduces the water table and renders the peat extremely dry. This also renders the area vulnerable to flooding in the rainy season due to decrease water holding capacity of peat. On top of all of these issues, the fire management system in Indonesia remains response-oriented, focused on fire-fighting paradigms that are developed for bush fire management in dry climates, as opposed to fire risk mitigation in

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degraded tropical peat lands. This mismatch means fire-fighting activities are ineffective in both responding to peat fires and mitigating future risk of such fires.

At the core, the GAMBUT Project is a Fire Risk System (FRS) developed by Bogor Agricultural Institute or Institut Pertanian Bogor (IPB) and Columbia University, with previous support from the UN Office for REDD+ (Reducing Emissions from Deforestation and forest Degradation in Developing Countries) Coordination in Indonesia (UNORCID) and USAID. The FRS encompasses four key elements of weather, fire history and biophysical factors leading to fire risk, ENSO patterns, and climate prediction tools based on forecasts of the Agency for Meteorology, Climatology and Geophysics or Badan Meteorologi, Klimatologi, dan Geofisika (BMKG). The FRS is a multi-functional tool that provides a probabilistic forecast to policymakers of the likelihood of fire several months in advance. Information from FRS can also be used to measure reductions in fire vulnerability from year-to-year. Fire vulnerability maps then inform decision makers of the most appropriate areas for peatland rehabilitation. The system shows what types of variables –whether biophysical or socio-economic– are the strongest indicators of fire vulnerability, which is important to know when deriving policy solutions around land use, cropping patterns, and more.

With early anticipation of fire hotspots, governments will be able to tailor preventive actions and mobilize resources to specific fire hotspots in Indonesia, based on predicted fire risks. The FRS tool must be accompanied by support from government and non-government stakeholders in order to sustainably mitigate fire risk by structuring and streamlining fire risk mitigation activities into development planning. Learning from the previous Indonesia Forest and Climate Support (IFACS) project and now working alongside LESTARI project’s partners (both are USAID forestry flagship projects) focused on environmental governance, GAMBUT is well positioned to achieve this multi-pronged approach. And by using an innovative tool explicitly facilitating action at a longer time-scale and national frameworks while providing guidance to local government, GAMBUT will empower governments and communities to develop locally-driven solutions to fire risk reduction.

This project aligns closely with the OFDA Washington focus on prioritizing and strengthening early warning, preparedness, mitigation and prevention of hazards.  In addition, it closely aligns with USAID/Indonesia objectives under DO 3 (Global Development Priorities of Mutual Interest Advanced).  It also builds upon previous work supported by USAID through the University Partnership Program between Columbia University and the IPB to mitigate and adapt to climate change through research and preventative action on peat fires.  

2.2 DESCRIPTION OF ACTIVITIES

The GAMBUT Project is broken down into the following component activities, which some of those are already completed and the rest are still ongoing until the end of project, as follows:

COMPLETED ACTIVITIES Vulnerability Mapping Toolkit: This toolkit comprised guidelines to national and provincial policymakers on how policymakers use the FRS tools, specifically the vulnerability maps, to mainstream fire risk mitigation in spatial and development planning. It showed how the maps

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within FRS can be used for benchmarking achievement in risk reduction, by identifying reductions in vulnerability year after year. Vulnerability Mapping Approach Training: In each of the eight districts, as well as at the provincial level, participants were trained on how to use the vulnerability mapping approach for social and economic development, spatial planning and annual budgeting. Model Development in West Kalimantan: The fire vulnerability map had already been created for West Kalimantan, an assessment of the statistical relationship between climatic factors and fire incidence was conducted under this project. A thorough field-based study was conducted to ensure FRS model findings are in line with field observations. Automation of Vulnerability Mapping: Automating FRS helped local governments to evaluate and assess the impacts of changes to the spatial plans on fire vulnerability by testing different scenarios. It helps planners to identify spatial plans with low fire risk and subsequently aid them in developing programs to anticipate the consequences of adopting specific spatial plans. Development of an Alert System: The alert system provided information on anticipated hotspots as well as anticipated impacts on air quality and fine particle density by informing users when there is extreme prediction or high-risk of fire beyond a certain level. The information is an SMS based and is integrated with fire prevention control centres as well as planning processes. South-South Technical Exchange: Under this project, UNORCID/UNOPS led a technical exchange between Indonesian government and non-government counterparts and the South African NGO, Working on Fire (WoF). During the exchange, WoF presented its program and discuss applicability in Indonesia during field visits to target provinces of Riau and Central Kalimantan. UNORCID/UNOPS also led an exchange trip to South Africa to visit WoF's training facility and community-based fire-fighting team and provided follow-up technical assistance from WoF to their Indonesian counterparts.

Option Identification Survey: Using a participatory and gender-based approach, together with community representatives, technical agency staff and experts, surveys were held at district and at the provincial levels and were to develop a number of technical options proven to reduce peat fire risk specific to each district. Given the complex social, economic, and biophysical dynamics that vary from district-to-district, fire risk mitigation requires addressing peatland ecology, agricultural livelihoods and incentives for land-use change systematically in each location. For example, needs might include construction of canal barriers using materials such as soil bags, rubber, and wood. Other actions included outreach to smallholders to promote alternative livelihoods options beyond palm oil, or alternative land use patterns. These surveys were critical to building the capacity of local government officials and community members to collectively identify key fire prevention actions in their communities. Identified options were screened using a simple multiple variable assessment tool and two to three scenarios were developed to test options and implement viable approaches. Scoping Study for Awareness Raising in Papua: A scoping study in Papua was conducted to assess the potential future implications of land clearing processes and fire vulnerability. The objective for

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this study is to identify mechanisms in Papua for anticipatory fire management in development processes which could be employed to mitigate fire risk before situation progresses. Policy Development Training: Using FRS outcomes, organized trainings for district and provincial parliamentarians, local officials, communities and private sector companies; these trainings enable them to understand how to use the FRS to identify better policies and land use planning decisions. Community Engagement: Using the enhanced web and mobile-based component of the FRS, outreach and awareness raising activities were conducted to improve knowledge throughout the community, including the private sector, and amongst government officials at the provincial and district level about the risk and impact of fires. Facilitate a participatory stakeholder led design of policy incentives and disincentives: The project supports integrated environmental and economic analysis based on an existing systems dynamics-based assessment tool (the Kalimantan Tengah Green Economy Model, or KT-GEM) for two initial districts, and an incentive/disincentive pilot will be designed. The outcomes are being used to inform national level policy makers on budgetary and planning implications through workshops and UNORCID dialogue activities. Building awareness through stakeholder engagement: activity was implemented to ensure adoption and use of the information generated by the FRS, with the aim of facilitating and promoting improved anticipatory fire management. International best practices and knowledge management: As part of sharing knowledge and information in fire risk management, the GAMBUT project, South-South learning exchange, and related FRS were highlighted as part of Global Peat Land Initiative (GPI) of which project’s implementing partner, UN Environment is also a member. As peat fire are becoming common in Democratic Republic of Congo, Republic of Congo and in the amazon basin, GAMBUT will play a key role in sharing knowledge during the third GPI partner’s meeting in the Republic of Congo in March 2018. South-South high-level exchange between Indonesia and South Africa on Integrated Wildfire Management Solutions: GAMBUT project had facilitated a South-South technical exchange between relevant Indonesian actors and the South African organisation, Kishugu, in August 2016, through an exchange trip of Indonesian participants to South Africa to visit Working on Fire (WOF)’s training facility, operations and communities where WoF has trained fire-fighting teams. The first technical exchange sought to evaluate potential lessons for the reformation of Indonesia’s recruitment and training of forest firefighters and explored the potential to transfer elements of the South African model to Indonesia. Given the success in the previous study tour, in April 2018 GAMBUT organized a high-level exchange to pick up on the technical work done in the first exchange, but with strategic emphasis on governance arrangements, funding and implementation models for achieving these aspects in Indonesia on a countrywide scale.

ONGOING ACTIVITIES

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Integration of BMKG Rainfall Forecast System: The FRS integrates BMKG’s forecasting data into the tool. Integrating BMKG’s forecasting system and historical data are important for government ownership of the FRS, while allowing model improvements. Provide support for small scale fire prevention activities through livelihood and paludiculture activities. To support innovation and strengthen learning on addressing fire prevention, small scale grants are provided to villages to initiate innovative approaches to address fire vulnerability in areas identified as highly vulnerable. GAMBUT Project is supporting the local government of Barito Selatan to test technically sound peat rehabilitation methods in Central Kalimantan to prevent further degradation, land subsidence and fire outbreaks which cause major haze related air pollution through canal blocking activities. On the original plan, community grants will be distributed to communities living around the area that has been hydrologically rehabilitated through the support of the canal blocking in Barito Selatan, Central Kalimantan. However, upon further consultation GAMBUT Project learned that the government through the Public Works has allocated state budget for canal blocking activity in the same location. Therefore, alternate conservation agriculture approaches which involves use of mulches, composters, cover crops etc. will be explored. An option that may offer a solution is the development of paludiculture, which is the cultivation of crops that are adapted to wet soil conditions. Paludiculture can be commercially planted on rewetted peatlands and can thus be used in rehabilitation efforts as an alternative to palm oil production. Several alternatives such as gemor, jelutung, rattan, and sagu can be explored. Communities have also expressed interest to engage in aquaculture activities. The objective of this activity is to promote rehabilitation activities through the participation of local communities, with the aim of reducing fire vulnerability around the area rehabilitated by GAMBUT. This activity will support the sustainable management of peat environments and move people away from slash and burn practices. Technical Assistance: A key activity is to ensure that anticipatory fire management is mainstreamed in the budgeting process and fiscal policies. This is achieved by providing technical assistance, on an as-needed basis, to district and provincial-based stakeholders. Enhance Fire Suppression: activity is implemented in Central Kalimantan to enhance the effectiveness of fire suppression and reduce fire brigades’ exposure to peat fires and haze. This is implemented by providing Personal Protective Equipment and Personal Protective Clothing to Masyarakat Peduli Api (MPA) members or community firefighting groups in six villages in Pulang Pisau District in Central Kalimantan. The MPA is also trained on fire suppression by firefighting professionals. Fire Risk System refinement and integration: Improvement of hotspot prediction model of the FRS with the use of onset prediction to support the FRS integration with InAware and Peta Bencana developed by Pacific Disaster Center for BNBP which leverages on an existing USAID funded project. Integration will be completed once FRS handover issue is resolved. Improving the FRS modelling and automation hotspot event with new on set date showing start of rainy season. FRS will be integrated with Sistem Informasi Data dan Indeks Kerentanan or Vulnerability Index Data and Information System (SIDIK), which is Government of Indonesia’s Climate Risk Vulnerability tool subject to hand over of FRS to Ministry of Environment and Forestry (MoEF) and latter’s approval. Aligning FRS with SIDIK which produces a vulnerability index, will combine social, economic and biophysical vulnerability criteria. This can be used to assess performance and guide

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jurisdictions to address vulnerability to fire, hence reduce fire risks and fire related Greenhouses Gas (GHG) emissions. Expansion of FRS coverage: To widen the current geographic coverage from Central Kalimantan and Riau to include also West Kalimantan and South Sumatra. Current district level presence will be slowly phased out and emphasis will be on provincial presence in the identified areas (Riau, Central Kalimantan, South Sumatra and West Kalimantan). Project presence will be limited to provincial level with the aim to enhance geographical coverage and facilitate only with the Department of Climate Change Control at provincial level, while liaising with the districts through them. At Central Kalimantan and Riau where we have current presence, the focus will be on sustaining impact and provide support with the continuous emphasis on the use of FRS in planning and fire suppression. Training in the use of FRS will be provided by IPB’s Centre for Climate Risk and Opportunity Management (IPB-CCROM) in West Kalimantan and South Sumatra. FRS maps for West Kalimantan and South Sumatra already exist, but knowledge on use of the system for fire prevention in these two provinces is non-existent. By working with government stakeholders in two additional provinces it is expected that the impact of FRS forecasts can be used by a much wider number of government counterparts further contributing to reducing fire vulnerability on the Indonesian peat landscape. Institutionalizing WOF model to MPA: Masyarakat Peduli Api (MPA) or Community Firefighting Groups is a key stakeholder for GAMBUT project and to build upon the existing work done so far, it is proposed to further institutionalise this model. Community firefighting curriculum is proposed to be included in a national level training of trainers through another USAID funded initiative supporting BNBP in collaboration with US Forestry Services using Incident Command System (ICS). Incident Command System is a management concept developed by the United States that originated from the handling of considerable forest fire incidents in California in the 1970s. It is applied at operational and tactical level to strengthen emergency disaster response command system. This activity will be implemented in collaboration by WOF. Canal blocking: this activity is no longer in the plan as the Public Works has budgeted canal blocking activity in the area where GAMBUT Project works, and based on the agreement with the local government, Public Works, and Peat Restoration Agency, the canal blocking in Barito Selatan will be done by Public Works and GAMBUT Project should focus only on the peat rehabilitation and community revitalization.

National Disaster Management Agency or Badan Nasional Penanggulangan Bencana (BNPB) aerial firefighting resource scoping: It is a national priority to ensure that no fire disasters and haze events occur during the 2018 fire season, with a special focus on the Asian Games (August) and local government elections (June). The scoping exercise will provide a high-level assessment of the aerial firefighting capability and readiness of BNPB, based on the following focus areas and examples of elements to be investigated: strategy, resources, systems, and infrastructure.

At this point, there is no evidence which shows any adverse impacts to the environment from the completed and ongoing activities. Detail mitigation and monitoring measures for those activities are described in section four and five of this IEE.

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3.  COUNTRY AND ENVIRONMENTAL INFORMATION

3.1 LOCATIONS AFFECTED

GAMBUT covers eight districts across Riau (Sumatra) and Central Kalimantan, as well as preliminary activities in West Kalimantan and Papua, targeting scoping and awareness raising exercises in these latter two areas. These locations were chosen based on data on most fire prone districts as well as overlap with other USAID projects, specifically the former IFACS Project and the ongoing LESTARI project in Central Kalimantan, West Kalimantan and Papua. Target districts include:

Riau Province: Bengkalis, Rokan Hilir, Siak and Dumai Districts: These districts are of strategic importance, as they comprised largely of peat land and are primarily located along the coast of Sumatra and are some of the most fire vulnerable districts in Indonesia. IPB and CU have previously been working specifically in Bengkalis District.

Central Kalimantan Province: Kapuas, Pulang Pisau, Barito Selatan and Palangkaraya Districts: These areas have been significantly affected by the ex-Mega Rice project and now suffer from repeated peat fires.

West Kalimantan: West Kalimantan is also a strategic location for the project due to the geographic location, and the biophysical and socio-economic dynamics its’ peat ecosystems.

Papua: If nothing is changed, Papua appears to be heading in the same direction as Riau in terms of land use change and fire risk. In order to avoid following this downward trajectory, GAMBUT will undertake exploratory work and awareness raising exercises in Papua.

In addition to specific activities targeted within these priority landscapes, GAMBUT will engage at the national level on governance, coordination, and evidence-based decision making. These national-level interventions are expected to influence fire risk reduction and risk-based land use planning and policy decisions across Indonesia. UNOPS widens the to include West Kalimantan and South Sumatra in the latest award amendment.

3.2 NATIONAL ENVIRONMENTAL POLICIES AND PROCEDURES

The Environmental Protection and Management Law of 2009 establish a framework for environmental planning, environmental impact analysis and licensing, and rights, responsibilities and penalties. Designed to supplant previous environmental legislation (No. 23/1997), the Law requires regional governments to formulate environmental protection and management plans and to conduct Strategic Environmental Assessment or Kajian Lingkungan Hidup Strategis (KLHS) to be used as a basis for regional development planning. It also stipulates that activities expected to have an impact on the environment are required to undergo an Environmental Impact Analysis or Analisis Mengenai Dampak Lingkungan (AMDAL), or to develop an Environmental Management and Monitoring Plan or Upaya Pengelolaan dan Pemantauan Lingkungan (UKL-UPL), depending on the nature of the activity, as a condition for obtaining an environmental license. An AMDAL is equivalent to an Environmental Impact Statement (EIS) by USG definition and is required following a Positive Determination in an IEE. The implementation of Environmental Protection and Management Law of 2009 is governed by Ministry of Environment Regulation No. 5/2012 and No.

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13/2010.

4.  EVALUATION OF POTENTIAL ENVIRONMENTAL IMPACTS

While development activities are intended to provide cross-sectoral and community-level natural resources management, when managed ineffectively they may cause adverse impacts that can offset or eliminate these intended benefits. Impacts can be direct, indirect, or cumulative.  They can also be beneficial or negative. The USAID Sector environmental guidelines at http://www.usaidgems.org/sectorGuidelines.htm offer a good resource in finding more information on potential impacts for various sectors.

GAMBUT components cover a broad range of interventions across the forestry, land use and governance sectors, including community-level natural resources management, and many of these interventions are not expected to have an adverse impact on the environment.  Certain activities proposed under the Program may, however, have impacts on the natural or physical environment if not designed and implemented using sound environmental principles.  These activities may include: spatial and land-use planning, small-scale construction activities designed to assist communities with peat fire prevention, such as interventions used to reroute, control, and collect water; assistance in agricultural practices such as small scale irrigation systems, alternative crops or cropping patterns, or modified land use patterns; peat forest or agricultural land rehabilitation and reforestation.

Program activities might also include policy development (to include fiscal incentives and/or reforms), such strengthening the capacity of relevant local government entities around fire risk reduction processes, and mainstreaming fire risk reduction measures into development planning and annual work plans of local and provincial governments. Potential negative environmental impacts from these activities may include increased human access/opportunity to exploit natural resources; degraded ground/surface water quality; generation of solid waste during construction; habitat disturbance/ degradation; and creation of perverse incentives for unsustainable practices.  Because of diverse nature of conditions at the locations under GAMBUT, it is difficult to predict specific activity impacts. At this point, there is no existing evidence that proves the canal blocking or fire prevention activities would make negative impact to the environment.

5. RECOMMENDED THRESHOLD DECISIONS AND MITIGATION ACTIONS

5.1 RECOMMENDED THRESHOLD DECISIONS AND CONDITIONS

Many of the GAMBUT activities described in Section 2.2 justify Categorical Exclusions, pursuant to 22 CFR 216.2(c)(1) and (2), for which an IEE, or an Environmental Assessment are not required because the actions do not have an effect on the natural or physical environment.

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Specifically, as currently planned, such activities fall into the following classes of action:(a) Education, technical assistance and training (216.2(c)(2)(i));(b) Analyses, studies, and workshops (216.2(c)(2)(iii));(c) Controlled experimentation exclusively for the purpose of research and field evaluation

which are confined to small areas and carefully monitored (22 CFR 216.2(c)(2)(ii));(d) Document and information transfer (216.2(c)(2)(v)); and,(e) Activities that will develop the capability of recipient countries to engage in development

planning (216.2(c)(2)(xiv)).

As currently planned, none of the above actions are expected to directly affect the environment.

Pursuant to 22 CFR 216.3 (a)(2)(iii), a Negative Determination with Conditions is recommended for the following classes of activities: spatial and land-use planning, small-scale construction activities designed to assist communities with peat fire prevention, such as interventions used to reroute, control, and collect water; assistance in agricultural practices such as small scale irrigation systems, alternative crops or cropping patterns, or modified land use patterns; and peat forest or agricultural land rehabilitation and reforestation. When implemented ineffectively they may cause adverse impacts that can offset or eliminate the intended benefits. Mitigating environmental impacts with these activities requires a participatory approach to activity/program design and management. Strong technical design of the projects is also critical. Irrigation or water management system for certain condition have been determined generally to have a significant effect on the environment, and an Environmental Assessment or Environmental Impact Statement, as appropriate, will be required, but in this case the project will limit the activity for only small scale system (see Annex 1).

According to government regulations from Ministry of Environment No. 5/2012 and No. 13/2010, small scale activities such as construction, irrigation, or water management system does not require Environmental Impact Analysis, if designed and implemented using sound environmental safeguards policy and procedures.

5.2 MITIGATION, MONITORING, AND EVALUATION

UNOPS as part of the United Nations entity is a Public International Organization (PIO) and an approved PIO grant recipient partner of USAID. This organization has long-established environmental assessment, monitoring and mitigation policies which meet the standards of those outlined by 22 CFR 216. Accordingly, the following are specific conditions to mitigate the potential negative impacts for respective sectors:

1. For activities that have the potential to result in significant adverse environmental, health, and safety impact, UNOPS will exercise its own Environment, Health, and Safety Safeguards policy and procedures.

2. If at any time the activities are found to be out of compliance with those requirements, UNOPS will immediately notify the Assistance Officer’s Representative (AOR) in Washington, D.C. and/or its alternate at the Mission, who in turn will notify the USAID/Indonesia Mission Environmental Officer (MEO).

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3. UNOPS will report to the AOR/alternate with a copy to the MEO, on the status of compliance of the UNOPS activities with those requirements above, including any corrective and preventive actions that have occurred.

6. LIMITATIONS AND REVISIONS

6.1 LIMITATIONS

This IEE does not cover direct activities listed below, that: ● Normally have a significant effect on the environment under 22 CFR 216.2(d)(1);● Affect endangered species; ● Result in wetland or biodiversity degradation or loss; ● Support extractive industries (e.g. mining and quarrying); ● Promote timber harvesting; ● USAID Global Development Alliance (GDA) and Development Credit Authority (DCA)

program;● Provide support for regulatory permitting; ● Result in privatization of industrial or infrastructure facilities; ● 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 and/or pesticides;

● Procure or use Genetically Modified Organisms (GMOs); and,● Introduce new species or varieties.

Any of these actions would require an IEE to be approved by the Bureau Environmental Officer.

6. 2 REVISIONS

If during implementation, project activities are considered outside of those described in this document, an amendment shall be submitted. Pursuant to 22 CFR 216.3(a)(9), if new activities are added and/or information becomes available which indicates that activities to be funded by the project might be “major” and the project’s effect “significant,” this determination will be reviewed and revised by the AOR of the project, and submitted to the MEO and BEO for approval and, if appropriate, an environmental assessment will be prepared. This IEE shall also be amended when the funding level is increased beyond $250,000; and the LOP duration is extended beyond six months.

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APPROVAL OF ENVIRONMENTAL ACTION RECOMMENDED

CLEARANCE:

ENV: ________________________ Date: __________Jason SeucUSAID/Indonesia – acting Environment Office Director

MEO: ________________________ Date: __________Putu KurniawanUSAID/Indonesia – Mission Environmental Officer

RLO: ________________________ Date: __________Betty ChungUSAID/Indonesia – Resident Legal Officer

REA: ________________________ Date: __________Christopher DegeUSAID/RDMA – Regional Environmental Advisor

DDIR: ________________________ Date: __________Betty ChungUSAID/Indonesia – Acting Deputy Mission Director

DECISION OF USAID/INDONESIA MISSION DIRECTOR By signing below, you approve the IEE Amendment#2 to Asia 15-078 PIO Grant to UNOPS for GAMBUT

APPROVAL:

DIR: ______________________ Date: __________Ryan WashburnUSAID/Indonesia – Acting Mission Director

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DECISION OF THE ASIA BUREAU ENVIRONMENTAL OFFICER By signing below, you approve the IEE Amendment#2 to Asia 15-078 PIO Grant to UNOPS for GAMBUT

CONCURRENCE:

BEO: _____________________ Date: ___________William GibsonAsia Bureau Environmental Office

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ANNEX 1

Limitation for Small Scale Irrigation and Water Management SystemAccordance with Government of Indonesia law from Ministry of Environment Regulation no.5/2012 about List of activities required Environmental Impact Analysis – similar with Environmental Impact Statement.

No Type of the activity Scale1 Dam construction or other

impoundmentsHeight ≥ 15 mCapacity ≥ 500.000 m3Area ≥ 200 ha

2 Irrigation System New system ≥ 3000 haAdditional system ≥ 1000 haRice field (in group) ≥ 500 ha

Note: below those limit, the project should simply prepare Environmental Management/ Environmental Monitoring Plan (UKL-UPL) – similar with Environmental Monitoring and Mitigation Plan (EMMP).

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