The Programmatic Initial Environmental Examinationof the Food for Peace FY15 Request for Applications (RFA)

for USAID Development Food Assistance Projects

PROJECT/ACTIVITY DATA:Title of Project: Office of Food for Peace (FFP), Bureau for Democracy, Conflict and Humanitarian Assistance (DCHA), DCHA/FFP

Operating Unit Grant Number(s): To be determined upon award(s)

Country/Region: Mali and Bangladesh

Implementing Partner:  To be determined upon award(s)

Funding: Described in the RFA, http://www.usaid.gov/sites/default/files/documents/1866/Draft%20FY%202015%20RFA%20for%20Bangladesh%20and%20Mali.pdf.

IEE Drafted by: Global Environmental Management Support Contract (GEMS)

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)

The overall environmental determination is a Negative Determination with Conditions. All other activities are to receive a Deferral until specific project activities are defined.

Request for Categorical Exclusion(s): activities have no adverse effect (i.e. training, technical assistance; not to include any infrastructure rehabilitation).

X Negative Determination: no significant adverse effects expected for activities which are well defined over life of the award, if implemented with conditions or mitigation measures specified to ensure no adverse effect.

Positive Determination: potential for significant adverse effect of one or more activities; appropriate environmental review required.

X Deferral: elements not well defined; activities will not be implemented until Project IEE is approved.

SUMMARY OF FINDINGS:The current Food for Peace (FFP) Request for Application (RFA) describes how USAID FFP environmental compliance will be met through BOTH 1) a single high-level, programmatic RFA IEE and 2) multiple, supplemental IEEs (Project IEE)1 that describe potential environmental risks and impact pertaining to the specific baseline of the awarded project. The overall purpose of this current RFA-level Initial Environmental Examination

1 Applicants will note that several changes were instituted in the FY14 FFP RFA concerning environmental safeguards and compliance, as compared to solicitations issues prior to FY14.

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(“RFA IEE”) is to establish environmental compliance policies and procedures for the

current FFP Development Food Assistance RFA. The current RFA IEE provides instructions for safeguarding and 22 CFR 216 compliance across multiple stages of both project design and implementation. These stages include 1) during project design by USAID during the solicitation development, 2) during specific proposal development by the applicant, 3) once USAID notifies applicants on the intent to award and, 4) after award is signed, and 5) once project start-up and implementation in the field is conducted.

This strategic, RFA-IEE developed by USAID will be supplemented by award and project specific IEEs that are developed by the FFP implementing partners to describe potential environmental risks and impacts pertaining to the specific ecological and community capacity baseline.

ENVIRONMENTAL THRESHOLD DETERMINATIONS:There are certain activities, routinely implemented by all FFP projects, that are recommended for a Negative Determination with Condition, pursuant to 22 CFR 216.3(a)(2)(iii):

1. Commodity warehouse fumigation activities; and

2. Energy provision for food/commodity cooking activities.

A Deferral is recommended for all other project activities pursuant to 22 CFR 216.3(a)(7)(iv) that cannot be addressed in this programmatic IEE at this stage of solicitation. Project IEEs will need to be developed once USAID makes apparent its intention to fund a project proposal. Project IEEs will analyze potential impacts of all project activities and resolve all applicable Deferrals recommended in this RFA IEE.

SUMMARY OF MITIGATION CONDITIONS:In light of the environmental integration effort, described in the FFP RFA, environmental safeguards must be integrated into proposal development, project design and implementation. All projects must be designed in accordance with the following common conditions and specific conditions, listed separately below:

I. Common Conditions Relevant to Environmental Integration Effort: The following general conditions are relevant to the initiative to integrate environmental safeguards into the project design during the proposal development stage, as described in the current RFA.

1. Environmental Safeguards PlanThe environmental safeguards plan, as described in the CURRENT FFP RFA, must be included as an Annex in all proposals to describe environmental risk and mitigation measures that are relevant to a particular country and project.

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2. Commodity Fumigation All FFP project proposals must include measures to ensure safe and effective commodity management and fumigation in accordance with the requirements found in USAID PROGRAMMATIC ENVIRONMENTAL ASSESSMENT (PEA) FOR PHOSPHINE FUMIGATION OF STORED AGRICULTURAL COMMODITY, http://www.usaidgems.org/fumigationPEA.htm.

3. Energy Needs for Commodity PreparationAll FFP project proposals must have provision for promoting safe and effective use of fuelwood, or other energy sources, used for commodity preparation by beneficiaries, integrated across all project designs. Projects planning activities with fuel-efficient cook-stoves will draw from the USAID Fuel-Efficient Stove Programs in Humanitarian Settings: An Implementer’s Toolkit.

4. Budget and StaffingBudget items, staffing and budget narrative description for all environmental safeguards integrated into project design: FFP requires that all projects have the necessary budget to achieve environmental compliance (as per ADS Chapter 204.2.c).

5. Global GuidanceIn addition to guidance in the Request for Applications (RFA), FFP applicants will draw from USAID and other donor country-level and global environmental assessments at the time of project and proposal design. Applicants are expected to draw from country-level USAID Environmental Threats and Opportunities Analyses (ETOA) and USAID 118/119 Biodiversity and Tropical Forestry Assessments.

II. Specific Conditions Relevant to the Project IEE: The following conditions are relevant to the development of the Project IEE, once USAID notifies the applicant of Intent to Award.

1. Project IEEs: Only apparently successful applicants will be required to submit Project IEEs to the AOR. Project IEEs must provide analysis and/or resolution of deferrals for all activities that are proposed by the project. Once project activities have been defined in detail, these Project IEEs must analyze potential environmental impacts from project activities based upon factors including the activities scale, country and intervention area-specific variables (e.g. baseline levels of environmental degradation). Project IEEs must propose all mitigation measures required to be implemented as part of project activities to mitigate their potential impacts.

a) Project IEE Deadline: Project IEEs must be submitted no later than the M&E workshop by all apparently successful applicants to the FFP AOR.

b) IEE Budgets: Additional environmental budgeting items that were not integrated into the initial proposal’s budget, which are identified during the subsequent development of the Project IEE, must be added prior to the signing of the final award.

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c) USAID IEE Clearance: DCHA/BEO required to clear on final IEE  and budgets prior to signing of the award.

2. Pesticide Use and Reporting Requirements: In the event that any of the project activities include the promotion, procurement, transport, storage or disposal of pesticides, prior approval from the DCHA/BEO is required under the guidance of an Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP), pursuant to 22 CFR 216.3(b).

a) Omissions: This current RFA IEE does NOT address any agricultural or human health/vector control pesticide uses, including their promotion, procurement, transport, storage or disposal. Additional analytical review and clearance by the DCHA/BEO is required prior to any project’s procurement or promotion of pesticides, pursuant to 22 CFR 216.3(b), USAID’s Pesticide Procedures.

3. Annual Environmental Status Reports:  All FFP projects are required to produce Environmental Status Reports (ESRs) once a year. The ESRs will report out on the actions taken, staffing, budget, and monitoring plan for implementation of the IEE conditions and mitigation measures. Reporting will include discussion of results of environmental indicators in and efforts undertaken during the previous implementation year, as well as plans for environmental staffing, budget and mitigation plans for the next implementation year. 

4. Monitoring and Evaluation of FFP Projects: As required by ADS 204.5.4, the AOR, in consultation with FFP projects, FFP Project Managers, Mission Environmental Officers (MEO) and/or the DCHA Bureau Environmental Officer (BEO) will actively monitor and evaluate whether environmental consequences unforeseen by this current RFA IEE and subsequent Project IEEs, arise during implementation and modify or end activities as appropriate.

5. Compliance of FFP Projects with Partner Country Regulations: Implementation will in all cases adhere to applicable partner country environmental laws. The IEE supports and strengthens the rule of law for systems of environmental governance in partner countries.

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USAID APPROVAL OF ENVIRONMENTAL ACTION(S):

Clearance:FFP Director: _______________Cleared________ Date: 9/19/2014

Dina Esposito

FFP Program Officer: ________Cleared___________ Date: ___9/19/2014

Susan Bradley

FFP Grants Manager: ______Cleared_____________ Date: 9/19/2014

Juli Majernik

Concurrence: DCHA Bureau Environmental Officer: Cleared Date: 9/22/2014

Erika J. Clesceri, Ph.D

CC to:

Africa Bureau Environmental Officer (BEO)

East Africa Regional Environmental Adviser (REA)

Southern Africa Regional Environmental Adviser (REA)

All USAID environmental assessment documents are accessible on the USAID Initial Environmental Examination/Environmental Assessment (IEE/EA) Database.

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FFP RFA-IEE Table of Contents

1.0 Background and FFP Description______________________________________7

1.1 Background_________________________________________________________71.2 Description of FFP Project Activities______________________________________81.3 Purpose and Scope of current RFA-IEE__________________________________9

2.0 Country and Environmental Information____________________________________102.1 Locations Affected__________________________________________________10

2.2 National Environmental Policies and Procedures___________________________11

3.0 Evaluation of Project Issues with Respect to Environmental Impact Potential______12

4.0 Recommended Mitigation Actions (including Monitoring and Evaluation)_________14 4.1 Recommended current RFA-IEE Determinations___________________________144.2 Mitigation, Monitoring and Evaluation____________________________________14

5.0 Summary of Findings____________________________________________________19

Annex 1: Template for Project Initial Environmental Examinations__________________20

Annex 2: Food Commodity Protection PERSUAP Template________________________25

Annex 3: Fumigation Management Plan Template ________________________________37

1.0 Background and FFP FFP Activity Description

1.1 Background

Food for Peace (FFP) provides development food assistance to target the underlying cause of hunger and malnutrition. The primary purposes of USAID development food assistance are to 1) reduce chronic malnutrition among children under-five years of age and pregnant and lactating mothers; 2) increase and diversify household income; and 3) strengthen and diversify agricultural production and productivity.

Various guidelines have begun to focus on the coordinated assessment of climate change and disaster risk reduction (DRR) issues as part of development assistance, whereas addressing environmental degradation has been pursued separately. Recent efforts have been made to target climate, environmental degradation and DRR jointly, as these stressors are most effectively addressed at the same time. Therefore, USAID environmental compliance will be met both through environmental integration and stand-alone efforts.

As part of the integration of safeguards into project design, applicants are to consider the four primary environmental goals of USAID FFP food assistance projects include:

1. Description of how project will plan to do no harm to local environment of land, water and flora/fauna, including humans (e.g., project-related deforestation, medical waste management, safe/effective pesticides, water quality assurance);

2. Description of how project will plan to improve community resilience to environmental degradation and climate-related shocks (e.g., potable water, groundwater-sourced irrigation, road durability/erosion, vector control);

3. Description of how project will plan to rehabilitate degraded natural resources that are relevant to project’s food security objectives (e.g., poor soil fertility, contaminated drinking water,);

4. Description of how project will plan to strengthen knowledge, attitudes and practice of target beneficiaries to better manage community natural resource environments for enhanced project sustainability and resilience to shocks related to food security.

To support achievement of food security objectives, FFP projects must integrate sound environmental design considerations into their project proposals. Furthermore, the Foreign Assistance Act of 1961, Section 117, requires that the impact of USAID’s activities on the environment be considered and that USAID include environmental sustainability as a central consideration in designing and carrying out its development objectives over the life of the project. This mandate is codified in Federal Regulations (22 CFR 216) and the USAID’s Automated Directives System (ADS) Part 204. This mandatory environmental compliance for the FFP projects will be met both through this strategic RFA Initial Environmental Examination (current RFA IEE), which guides the process for environmental integration as part of project design as well as the completion of stand-alone, project-

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specific IEEs (hereafter Project-IEEs).

1.2 Description of FFP Project Activities

USAID FFP works toward a world free of hunger and poverty. To this end, the FFP Office makes agricultural commodity donations to private voluntary organizations (PVOs) and international organizations (IOs), such as the UN’s World Food Program (WFP). FFP commodities are purchased from US farmers and shipped abroad from US ports.

In addition to agricultural commodity donation, FFP Program Elements, as defined in the RFA, may include any or all of the following:

1. Agriculture Sector Capacity: Reduce risks during the agricultural production cycle and increase agricultural productivity by encouraging activities related to a sustainable agriculture system.

2. Strengthen Microenterprise Productivity : Support the start-up and expansion of self-employment and micro and small enterprises owned and operated by low-income people.

3. Natural Resources and Biodiversity: Conserve biodiversity and promote natural resource management in a socially, economically, and environmentally sustainable manner while working to maximize return and predictability of income.

4. Civic Participation: Increase communities’ capacity to influence the factors that affect their food security, and strengthen the financial, management, and administrative capacity of the community and implementing partner organizations.

5. HIV/AIDS: Reduce the transmission and impact of HIV/AIDS through support for prevention, care and treatment programs.

6. Maternal and Child Health: Increase the availability and use of proven life-saving interventions that address the major killers of mothers and children and improve their health status.

7. Family Planning and Reproductive Health: Expand access to high-quality voluntary family planning services and information, and reproductive health care.

8. Water Supply and Sanitation: Activities include improving water and sanitation infrastructure, and resource management practices.

9. Nutrition: Increase availability and use of proven nutrition interventions to reduce mortality, morbidity, and food insecurity.

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10. Basic Education: Improve early childhood education, primary education, and secondary education, delivered in formal or non-formal settings.

11. Social Assistance: Activities include cash or in-kind transfers to the poor or those suffering from temporary shocks.

12. Protections and solutions: Ensure full respect for the rights of the individual and communities in accordance with the letter and the spirit of the relevant bodies of law (international humanitarian, human rights, and refugee law).

13. Capacity building preparedness and planning: Assist communities with efforts to reduce potential damage natural hazards such as earthquakes, floods, droughts, and cyclones can cause.

14. Assistance and recovery : Promote rapid and durable recovery in the aftermath of a disaster by supporting livelihoods, markets, and the sustainable provision of basic services.

1.3 Purpose and Scope of FFP RFA IEE

The FFP RFA describes the environmental safeguards and compliance for development food assistance projects. For RFA applicants, USAID FFP environmental compliance at the time of project design will be met through adherence to both 1) this RFA IEE and 2) completion of a stand-alone, Project IEE, only upon USAID’s indication of an intent to award. Once the Project IEE and attendant budget, are finalized and approved by the DCHA BEO, the IEE is to be used to guide project implementation. All mitigation measures contained in the IEE must be implemented and monitored for effectiveness in reducing the severity of potential environmental impacts resulting from project activities. The overall purpose of this Food for Peace RFA-level Initial Environmental Examination (RFA IEE) is to establish the environmental compliance process for the FFP Development Food Assistance Projects. This RFA IEE provides clear instructions for compliance at the time of application, once USAID’s intent to award is made apparent as well as, post-award, once project start-up begins.

This RFA IEE serves as a pre-award environmental-threshold decisional document for three purposes. First, to satisfy the legal 22 CFR 216/ADS 204 requirements for  disbursement of project funds; and Second, to reduce the burden of IEE development by providing impact analysis of activities common to all FFP projects. Third, it will allow for impact analysis to be grounded in more detailed information about the final project design. This RFA IEE also updates the current environmental compliance guidance, specific to Food For Peace projects and project-IEE development. These project IEEs, drawing from guidance found in this current RFA IEE, serve as project-specific analytical documents that describes the national and sub-national environmental baselines, potential environmental impacts and project-specific environmental mitigation measures, including required IEE implementation features of budgeting, monitoring and reporting.

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2.0 Country and Environmental Information

2.1 Locations AffectedBecause not all FFP intervention areas and activity details for the current round of programming have been identified, and because of the variety of environmental situations that might be encountered, this section of this RFA IEE can be neither comprehensive nor detailed.

Activities under FFP may take place in any of the countries covered by the RFA. All FFP projects must comply with partner country environmental statutes and USAID policy ADS 204. It is anticipated that projects and their activities could be carried out in multiple rural ecosystems and areas that are beset by poverty and/or are recovering from damage and destruction caused by military operations and insurgency activities. Because the specific characteristics and locations of these activities are not definitive, the potential for adverse environmental impacts cannot be determined until additional information about project design and location becomes available.

Project and proposal designs of applicants will address intervention area-specific physical and topographic conditions, climate, soils and ecosystems, as well as the national policies, on-going procedures and conditions, social and local characteristics that could be encountered. Projects will be designed to include:

Description of how project will plan to do no harm to the local environment of land, water and flora/fauna, including humans (e.g., project-related deforestation, medical waste management, safe/effective pesticides, water quality assurance);

Description of how project will plan to improve community resilience to environmental degradation and climate-related shocks (e.g., potable water, groundwater-sourced irrigation, road durability/erosion, vector control);

Description of how project will plan to rehabilitate degraded natural resources that are relevant to project’s food security objectives (e.g., poor soil fertility, contaminated drinking water,);

Description of how project will plan to strengthen knowledge, attitudes and practice of target beneficiaries to better manage community natural resource environment for enhanced project sustainability and resilience to shocks related to food security.

Applicants are expected to draw from existing USAID or other country-level environmental analyses, including Environmental Threat and Opportunity Analyses (ETOAs) and 118/119 Biodiversity and Tropical Forestry Assessments, which are developed by USAID bilateral or country Missions to integrate environmental concerns into annual Country Development Cooperation Strategy (CDCS) processes. These analyses are developed via consulting a wide variety of key stakeholders from government and civil society (including intended beneficiaries of programming). Additionally, applicants are strongly recommended to draw from key lessons learned from country-level climate change vulnerability assessments developed by USAID or other key entities. Examples of country-level climate change vulnerability assessments can be found at: http://www.worldbank.org/en/news/feauture/2011/06/06/economics-adaptation-climate-change-country-case-studies.

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2.2 Partner Country National Environmental Policies and Procedures

Implementation of all project activities will always adhere to applicable partner country environmental laws and best practice. Project IEEs will include descriptions of all relevant environmental policies and procedures. For reference, applicants preparing their Project IEEs are encouraged to source partner country environmental policy and regulatory framework information from past IEEs that are publically available at the USAID IEE/EA Database (http://gemini.info.usaid.gov/egat/envcomp/) and other existing multilateral donor or country assessments and reports, e.g. UNEP Environmental Profiles, Country Reports to the UN Convention on Biological Diversity, UNFCCC National Adaptation Programs of Action to Climate Change, etc.

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3.0 Evaluation of Project Issues with Respect to Environmental Impact Potential

Most of the USAID FFP projects’ activities are not well-specified at the time of the RFA. Sector and country baseline details, including scope and scale, will be identified during the proposal development and award process. As such, the extent of potential environmental impacts resulting from these activities cannot be well analyzed at this time.

However, there are a common set of activities: a) commodity fumigation activities and b) activities pertaining to the energy needs for commodity preparation that are routine for all FFP development assistance projects and have potential for environmental impacts, including impacts to humans.

A. Commodity fumigation activity issues

Use of the fumigants can potentially affect the health of applicators and other on-site workers and visitors.

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

The quality of the food commodity may be compromised due to fumigation. Beneficiary populations may be at risk from inhalation, preparation and ingestion

of fumigated commodities. Fumigation residuals can affect water quality, soil and non-target organisms. Poor practices in transport, storage, and disposal of fumigants are a concern for

human health Improper disposal practices of rodents and birds killed by fumigants could affect

human health. Fumigants may not completely control fungal contamination.

B. Energy needs for commodity preparation issues

USAID environmental compliance procedure 22 CFR 216.2(c)(2) cites “programs of maternal or child feeding conducted under Title II PL 480” as a class of action subject to a Categorical Exclusion classification. However, while this distribution of Title II commodity does not have a direct environmental impact, this activity may likely have indirect impacts. For example in communities relying on biomass for energy, a Maternal and Child Health/Nutrition food security project assisting 70,000 beneficiaries has an indirect impact of using 30,000 MT of fuelwood per year to prepare commodity. This estimate is based upon a conservative fuelwood consumption rate of 1 kg of fuelwood per person per day.

In many countries, there are various sources of energy used for cooking depending on where one lives and how much one can afford. These sources include but are not limited to wood and wood-based charcoal, coal and fuel bricks made from cow dung and straw, propane and kerosene in towns, diesel stoves, or gas or electricity in cities.  

In response to both rising fuel costs and natural resource degradation, it is important to

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consider:

the role that food basket items, particularly their type and age, play in affecting fuel requirements and natural energy resources;

the promotion of efficient fuel use (e.g. cooking with tight fitting lids on pots, etc.) and/or fuel-efficient cooking devices; and

the potential social impacts, such as competition, inequitable distribution or conflict over scarce energy resources.

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4.0 Recommended Mitigation Actions (Including Monitoring and Evaluation)

4.1 Recommended FFP RFA IEE Determinations

The overall environmental determination for a FFP award under this current RFA IEE is a Negative Determination with conditions for all 1) commodity fumigation activities and 2) activities pertaining to the energy needs for commodity preparation as these activities are a routine part of every FFP project. Due to the fact that other individual project activities are not well defined until post-award, all other activities have received a Deferral.

A Negative Determination with Conditions, pursuant to 22 CFR 216.3(a)(2)(iii), is recommended for: all commodity fumigation activities and activities pertaining to the energy needs for commodity preparation implemented under projects because these activities have potential for negative impact on the environment and mitigation measures are required.

Please note that this current RFA IEE does not address other agricultural or vector control pesticide uses, including their promotion, procurement, transport, storage or disposal. Additional analytical review and clearance is required for these chemical controls by the DCHA/BEO pursuant to 22 CFR 216.3(b), USAID’s Pesticide Procedures.

Deferrals are recommended for all other project activities pursuant to 22 CFR 216.3(a)(7)(iv) as per this current RFA IEE.

Project IEEs must provide analysis and/or resolution of these initial deferrals. These Project IEEs will analyze potential environmental impacts resulting from country and intervention area-specific variables and develop mitigation measures to be implemented as part of project activities once project activities have been defined in detail.

4.2 Mitigation, Monitoring and Evaluation

Environmental Procedures at the Project LevelProject IEE: As summarized in Figure 1, the RFA IEE will be supplemented with the Project IEE. A Project IEE will be developed to provide environmental impact analysis for all project activities so as to sufficiently describe the specific intervention area context and activities that will be carried out under the award. Project IEEs must be submitted no later than the M&E workshop by all apparently successful applicants to the FFP AOR. The DCHA/BEO must approve the Project IEEs before the implementation of activities described therein.

As annexure to all Project IEEs, apparently successful FFP applicants must complete an Environmental Mitigation and Monitoring Plan (EMMP) which serves as the implementation plan for the IEE analyses and all required 22 C.F.R 216 compliance actions to be taken by a

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given project. A template is provided on page 24. EMMPs are to consist of two parts: 1) Activity/Impact/Mitigation Table 1, and 2) Environmental Monitoring and Evaluation Report Table 2. Alternately these two tables can be merged into a single combined mitigation and monitoring table format, provided text is still of readable size and all required information elements are incorporated.

Figure 1. USAID FFP environmental compliance process.

Environmental Budgeting: FFP requires that all projects have the necessary budget to achieve environmental compliance (as per ADS Chapter 204.2.c). As with budgeting for any project costs, a degree of budget planning must logically occur at both the initial proposal development stage and detailed budgeting within the Project IEE to identify EMMP implementation costs. Additional environmental budgeting items that were not integrated into the initial proposal’s budget, which are identified during the subsequent development of the Project IEE, must be added prior to the signing of the final award. The DCHA/BEO/DCHA will be required to clear on final IEE budgets prior to signing of the award.

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

IEE Amendments: In the event that any new proposed activity differs substantially from the type or nature of activities described in a project’s IEE, or requires different or additional mitigation measures beyond those described in the Project IEE, an amendment to the IEE will be developed, including a revised EMMP. All amendments, are developed by projects, sent to FFP and reviewed for approval by the DCHA/BEO prior to activity implementation. EMMP revisions during the course of implementation, such as fine tuning mitigation measures or including additional analysis for unexpected impacts as deemed necessary by project management teams, are encouraged as part of any projects sound adaptive environmental management. It is important to note, such EMMP modifications do not require an IEE amendment, approved by USAID. However all EMMP changes and their rationale, should be reported upon in subsequent Environmental Status Report, described further below.

Environmental Status Reports (ESRs): ESRs are required to be completed by all FFP projects on an annual basis. The ESRs will report out on the implementation of the EMMP, which is the implementation and monitoring plan for the IEE. EMMP reporting will include discussion of results of environmental indicators as well as mitigation plans for the next year of activity implementation.

Sector Specific Mitigation Requirements:

A. Commodity Fumigation Mitigation RequirementsThe activities will require that the operator, carrying out the fumigation operation, holds official certification to perform the fumigation, uses fumigants according to the directions on the label, and follows all listed directions, precautions, and restrictions. Fumigants will be used only for commodities and sites specified by the label. When handling fumigant, protective equipment including gloves and masks will always be used and warning signs indicating presence of poison gas will be placed. No access is permitted until the storage space has been ventilated and gas levels drop to safe levels. To minimize the need for fumigation, all warehouses must be kept clean and food stacks on pallets must be kept at least 3.5 feet away from the walls. Stacks must be checked on a weekly basis and action taken immediately if any infestation is detected. Warehouse staff should be trained to minimize pest infestations, and stock levels must be minimized such that if infestation occurs, the magnitude of the problem is reduced.

USAID has developed an assessment of environmental and health risks in the fumigation of food aid commodity entitled USAID PROGRAMMATIC ENVIRONMENTAL ASSESSMENT (PEA) FOR PHOSPHINE FUMIGATION OF STORED AGRICULTURAL COMMODITY, http://www.usaidgems.org/fumigationPEA.htm. The PEA includes a Pesticide

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Evaluation Report and Safer Use Action Plan (PERSUAP) template, and complimentary Fumigation Management Plan (FMP), see Annex 2 and Annex 3, respectively. These tools are intended to assist in compliance with the Fumigation PEA’s requirement for completion of a project-specific PERSUAP and FMP reporting.

Please note that in the event that any project activities include the promotion, procurement, transport, storage or disposal of pesticides for agricultural or vector control uses, a PERSUAP for proposed pesticides must be approved by the DCHA/BEO before pesticides can be used or promoted by the project, pursuant to 22 CFR 216.3(b). PERSUAPs should be submitted with Project IEEs (or as amendments to Project IEEs) as soon as such activities are anticipated. More guidance on USAID PERSUAP development and reporting requirements can be found online here at: http://transition.usaid.gov/our_work/environment/compliance/ane/workshops/Jordan2007/day1/F/PrepPERSUAP.pdf.

The following are specific mitigation requirements for the fumigant phosphine:

Fumigation monitoring equipment:

Abundant evidence demonstrates that gas monitoring devices are critical to verify that phosphine concentrations are sustained at high enough levels to provide an effective “kill” treatment of the commodities. Equally, gas monitors are needed to ensure the safety of warehouse personnel and fumigators. Without these monitors, the fumigant applicator has absolutely no knowledge of the gas concentrations. At phosphine concentrations where one can smell the gas, the gas is toxic to human health.

Gas impermeable tarps:

Stacks in a warehouse are enclosed with plastic or tarps when fumigating with phosphine. Warehouse doors and vents, must be sealed during fumigation because gaps can result in gas to leak from the warehouse. In addition, fumigation tarps must not be re-used too often as this may weaken the tarps or result in torn tarps and, therefore, would not create a gas tight seal. The warehouse compound must not remain open during fumigation, as well, as this potentially exposes workers in adjacent warehouses, office workers, and others working on-site to phosphine gas. Placarding and other measures should be taken to ensure that no entry will occur in warehouses that are being fumigated.

Personal Protective Equipment (PPE) requirement:

PPE requirements for fumigation include half-face respirators with eye protective gear or full-face respirators, gloves, coveralls and closed-toed shoes with socks. If and when this fumigation equipment is not available, then FFP projects are prohibited from contracting with these Fumigation Service Providers. Alternatively, projects may make a proposal to their FFP AOR to procure only essential fumigation equipment as described above.

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TOPS Warehouse Safety Guide in Alignment with the USAID Fumigation PEA:

Please note that TOPS has released their Warehouse Safety Guide (November 2014) which is an additional excellent resource for awareness raising and education campaigns for warehouse commodity storage. The Warehouse Safety guide Posters which highlight fumigation are in compliance with the findings of the Fumigation PEA. http://www.fsnnetwork.org/warehouse-staff-safety-guide .

The TOPS Warehouse Staff Safety Guide is a unique tool, funded by USAID through a TOPS Program Micro-grant, that was developed by Project Concern International (PCI) and the TOPS Commodity Management Task Force. The purpose of the Warehouse Staff Safety Guide is to provide organizations implementing Title II programs with 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.

B. Energy Needs for Commodity Preparation Mitigation RequirementsAll FFP project proposals must identify in the proposal how applicants will promote efficient and effective use of fuelwood, or other energy sources, used in the preparation of commodity. Illustrative activities might choose to promote practices around use or design of cooking stoves that increase efficiency or cultivate improvements in community management of fuel wood lots or other energy sources. Cookstove projects will draw from USAID Fuel-Efficient Stove Programs in Humanitarian Settings: An Implementer’s Toolkit.

Activity design should incorporate approaches to promote safe and effective use of energy sources. Designs should accommodate the labor-intensive nature of fuel-efficient stove (FES) activities by budgeting sufficiently for staff with requisite technical backgrounds and time to successfully achieve the expected results of the FES activity.

Any FES program should include a strong monitoring and evaluation framework, including the collection of baseline data, stove testing and surveys of beneficiaries.

FES stove production strategies must focus on quality control and follow-on monitoring, to ensure that stove design standards are met and quality and performance does not deteriorate over time.

A stove won't save fuel if the beneficiary doesn't use it properly. Hence, training and education on proper use of the stove and efficient fuel preparation and cooking practices is extremely important.

Below are example mitigation actions that cooks can take to make energy use for commodity preparation more efficient. These actions can be transformed into education tools enhanced by illustrations and/or photographs and used in implementation of behavior

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change strategies as part of commodity distribution and nutrition activity design.

Cooking-pot management

Cover pot with a tight-fitting lid when not stirring or adding food. Put a heavy object on top of the lid if it is not tight enough. Use a pot size that corresponds to the quantity of food being cooked. Use a pot made of the best material for the food you are cooking. Use a pot size and shape appropriate for the stove being used. If two pots are available, begin warming a second dish by placing it on top of the main pot.

Stove/fire management

Do not over-fill the stove with fuel. Position your stove in a place where it is protected from strong winds. Clean and maintain stove as instructed.

Fuel management

Use only dry firewood. Cut firewood into small pieces. After cooking, completely extinguish the fire rather than allowing it to burn out on its own.

Meal planning

Presoak hard foods, such as beans and some grains in water for several hours before cooking. Use tenderizing methods, such as filtering water through ash, to cook beans.

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5.0 Summary of Findings

Refer to the summary of common and project-specific conditions as described in the IEE facesheet, pages 2-4.

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ANNEX 1: TEMPLATE FOR PROJECT OR AWARD-SPECIFIC INITIAL ENVIRONMENTAL EXAMINATION

FFP ENVIRONMENTAL COMPLIANCE FACESHEET for the [INSERT PROJECT NAME] INITIAL ENVIRONMENTAL

EXAMINATION

PROJECT AND ACTIVITY DATA:

Title of Project:

Implementing Partner/Country/Region:

Originating Office:

Agreement No:

Funding Period:

Life of Activity Amount: $XX,000,000 (Total metric tonnage request: XXX MT; 202(e) grant: $XXXX; ITSH: $XXXX

IEE Prepared by:

IEE Amendment: Date of Original IEE:

Amendment Purpose:

ENVIRONMENTAL ACTION RECOMMENDED: (Place X where applicable)

Categorical Exclusion:         Negative Determination w/ Conditions:   

Positive Determination:   Deferral:

SUMMMARY OF FINDINGS:

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APPROVAL OF ENVIRONMENTAL ACTIONS RECOMMENDED:

A. Mission Clearances

Mission Director _____________________________________________ Date: ____________

Mission Environment Officer (MEO)______________________________ Date:____________

Food for Peace Representative __________________________________Date: ___________

Regional Environmental Advisor (REA) ____________________________ Date: ___________

B. Food for Peace, Washington Clearances

Agreement Officer’s Representative (AOR) _________________________________________ Date: ___________

Agreement Officer (AO)/Director ________________________________ Date: ____________

C. Concurrence

Bureau Environment Officer, DCHA ____________________________ Date: ____________Erika Clesceri

Approved Not Approved

CC: Relevant Regional BEOs

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The following narrative should be organized around the major activity sub-headings, if the activity categories are rather distinct, e.g. road construction, agricultural development and irrigation works. Treat each major activity under each section. Alternatively, one could organize by activity and then each major heading would cover the Sections 1 to 4. The summary in Section 5 is to cover all categories addressed, with an overview of the summaries at the end.

1.0 BACKGROUND AND ACTIVITY DESCRIPTION1.1 Background

1.2 Description of Activities

1.3 Purpose and Scope of Project IEE

Describe why the activity is desired and appropriate, and outline the key activities proposed for FFP funding. A current activity description should be provided and the purpose and scope of the Project IEE indicated (e.g. amendment, why needed and what it covers).

2.0 COUNTRY AND ENVIRONMENTAL INFORMATION2.1 Locations Affected

2.2 National Environmental Policies and Procedures

This section is critical and should briefly assess the current physical environment that might be affected by the activity. Depending upon the activities proposed, this could include an examination of land use, geology, topography, soil, climate, groundwater resources, surface water resources, terrestrial communities, aquatic communities, environmentally sensitive areas (e.g. wetlands or protected species), agricultural cropping patterns and practices, infrastructure and transport services, air quality, demography (including population trends/projections), cultural resources, and the social and economic characteristics of the target communities.

The information obtained through this process should serve as an environmental baseline for future environmental monitoring and evaluation. Be selective in the country and environmental information you provide, as it should be specific to the activities being proposed.

Finally, indicate the status and applicability of host country, Mission, project procedures in addressing natural resources, the environment, food security and other related issues.

3.0 EVALUATION OF ACTIVITY/PROGRAM ISSUES WITH RESPECT TO ENVIRONMENTAL IMPACT POTENTIAL

This section of the project IEE is intended to define all potential environmental impacts of the activity or project, whether they are considered direct, indirect, beneficial, undesired, short-term, long-term or cumulative. Be clear and concise in the organization of this section.

4.0 RECOMMENDED MITIGATION ACTIONS (INCLUDING MONITORING AND EVALUATION)

4.1 Recommended Project IEE Determinations

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4.2 Mitigation, Monitoring and Evaluation

For each proposed activity or major component recommend whether a specific intervention included in the activity should receive a categorical exclusion, negative determination (with or without conditions), positive determination, etc., as well as cite which sections of Regulation 22 CFR 216 support the requested determinations.

Recommend what is to be done to avoid, minimize, eliminate or compensate for environmental impacts. For activities where there are expected environmental consequences, appropriate environmental monitoring and impact indicators should be incorporated in the activity’s monitoring and evaluation plan.

5.0 EXECUTIVE SUMMARY OF FINDINGS5.1 Environmental Determinations5.2 Conditions

This should clearly summarize the proposed environmental determinations and recommendations.

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ANNEX 1: ENVIRONMENTAL MITIGATION AND MONITORING PLAN (EMMP)

The following two template tables are required of all projects as annexure to the project IEE.2

Activity/Impact/Mitigation Table 1

Project Type Activity Description of Impact Prescribed mitigation measures

     

       

       

Environmental Monitoring and Evaluation Report Table 2

Description of

Mitigation Measure

Responsible Party for

Mitigation Measure

Implementation

Monitoring Methods

Estimated Cost

Results

Recom-mended Adjust-ments

Indicators Methods FrequencyDates

MonitoredProblems

EncounteredMitigation

Effectiveness

                   

                   

                   

                   

                   

                   

                                                         

2 For more general guidance on EMMPs, see Mitigation and Monitoring of the Africa MEO Resource Center: http://www.encapafrica.org/meoEntry.htm. .

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ANNEX 2: FOOD COMMODITY PROTECTION PERSUAP TEMPLATE

Please find a template for the PERSUAP:

PERSUAP: The PERSUAP is the required USAID assessment evaluating the economic, social and environmental risks and benefits of the planned pesticide use to determine whether the use may result in significant environmental impact. Word (62 KB)

http://www.usaidgems.org/Documents/FumigationPEA/PhosphineFumigPERSUAPtemplate_March2014.doc

ANNEX 3: FUMIGATION MANAGEMENT PLAN TEMPLATE

Please find a template for the FMP:

Fumigation Management Plan. A template that provides a step by step process to ensure safe and effective fumigation and train fumigation personnel. Word (98 KB)

http://www.usaidgems.org/Documents/FumigationPEA/Phosphide_FumigMangmtPlan_August%202014.docx

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