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U.S. Agency for International Development

INITIAL ENVIRONMENTAL EXAMINATION (IEE)

Timor-Leste Plastic Upcycling Alliance (PUA)

A. PROGRAM/ACTIVITY DATA:

Title of Program: Timor-Leste Plastic Upcycling Alliance (PUA)

Country/Region: Timor-Leste/Asia

Implementing Partner (if designated): Mercy Corps

Time Period: O/a July 2019 – o/a July 2022

Life of Activity Funding: $900,000.00

IEE Prepared by: Candido da Conceicao, EG Project Management Specialist

Date: June 25, 2019

IEE/CE Amendment (Y/N): No.

Environmental Action Recommended: (Place X where applicable)

Categorical Exclusion: ☒ Deferral: ☐

Positive Determination: ☐ Negative Determination with Conditions: ☒

CLIMATE RISK RATING(S): (Place X where applicable)

Low: ☒ Moderate: ☒ High: ☐

B. BACKGROUND AND ACTIVITY/PROGRAM DESCRIPTION

Purpose and Scope of IEE

The purpose of this document, in accordance with Title 22, Code of Federal Regulations, Part 216

(22CFR216), is to provide a preliminary review of the reasonably foreseeable effects on the environment,

as well as recommended

Threshold Decisions, for the activities detailed below. This document provides a brief statement of the

factual basis for Threshold Decisions as to whether an Environmental Assessment or an Environmental

Impact Statement is required for the activities managed under the scope of this document.

The activities under review are recommended for categorical exclusion and negative determination with

conditions.

Asia 19-064

TIMOR-LESTE

Background and Program Description

Timor-Leste’s natural beauty is rapidly deteriorating while dangers to human health and safety increase

due to its growing plastic waste problem. The lack of access to critical skills, knowledge, technologies,

partnership strategies, and policy enabling environment necessary to nurture the growth of an industry for

plastics recycling stifles creation of needed employment and entrepreneurship opportunities. Timor-Leste

has the urgent development challenge of large and rapidly growing volumes of plastic waste that cannot

be recycled domestically using conventional recycling business models and is unfeasible to export.

This activity will initially target Dili, the capital city of Timor-Leste and largest population and plastic

waste concentration center. However, opportunities to expand plastic waste supply chains, as well as

product distribution networks, to secondary cities and towns will be considered based on a strategic cost

feasibility and value for money analysis completed with USAID.

USAID is a critical member of the Plastic Upcycling Alliance. The Alliance’s overall aim is to catalyze

the creation and growth of plastics recycling industry creating and expanding valuable employment and

entrepreneurship opportunities that improve the natural beauty of Timor-Leste and health and safety of its

people. Therefore, its goal is to assist Timor-Leste to achieve ‘plastic neutral’ status whereby unnecessary

plastic use is curtailed and replaced, and up to 20% of Dili’s plastic waste is collected and recycled into

locally sought after products within three years. Under this goal are three Strategic Objectives (SOs): (1)

Reduce Plastic Use, (2) Increase Plastics Recycling, and (3) Improve Plastics Management.

The Alliance’s proposed solution is to facilitate and drive a ‘domestic recycling market system’ for plastic

waste, resulting in the sustainable removal of up to 20% of the 12.5 million kg of plastic waste produced

annually in Dili, Timor-Leste, while creating and enhancing much needed new enterprise and ‘green

collar job’ opportunities. Specifically, the solution will leverage new government policies, existing

municipal waste management systems and infrastructure, a booming construction economy, and the

business expansion interests of Caltech and Heineken to establish and support growth and linkages

amongst waste plastic collection, aggregation, processing, and recycling enterprises while simultaneously

stimulating vibrant markets for polymer-blended ‘e-construction materials,’ mainly road asphalt and

sidewalk paving blocks, made from the recycled plastic.

Illustrative activities include per objective:

2. Increase Plastics Recycling:

2.2 Competitive recycled plastics product line developed (R&D):

2.2.1 Analyze global best practices and lessons for applicability to local context

2.2.2 Conduct Market Analysis

2.2.3 Prototyping and testing of product line

2.2.4 New upcycling technologies introduced

2.3.1 Analyze and implement best options to increase product competitiveness and market share.

2.3.2. Install demo roads, walkways, parking lots, etc.

3. Improve Plastics Management

3.1 Policy enabling environment for plastics reduction and recycling improved:

3.1.1 Hold regular meetings of upcycling industry actors and stakeholders

3.1.2 Develop and implement plan of policy reforms for improving management of plastics

3.2 Evidence of impact produced:

3.2.1 Conduct baseline/end line analysis

3.2.2 Refine agenda and conduct research and impact assessments important to activity efficacy

3.3 Model of plastics management in small- to medium-sized cities produced:

3.3.1 Document model, lessons and recommendations for plastics management in small- to medium-sized

cities

3.4 Evidence and lessons disseminated:

3.4.1 Develop and implement strategic plan for communicating PUA lessons learned

C. COUNTRY AND ENVIRONMENTAL INFORMATION

Description of Environment

Timor-Leste is located in the Lesser Sunda Islands (part of the Australian continental plate), and

includes the eastern half of the island of Timor, the Oecussi enclave in West Timor, and the islands

of Atauro and Jaco (Figure 1). The total area encompassed is approximately 15,000 square

kilometers (1.5 million ha) which is a little larger than the State of Connecticut.

The total population of Timor-Leste is currently

estimated at over 1.2 million people (Timor-Leste

Population and Housing Census, 2015) with a

population growth rate of 2.2 percent per year.

Timor-Leste’s soils are generally thin, with poor water

holding capacity. The topography is quite dramatic,

with mountain peaks reaching as high as 2964 meters.

Over 78 percent of the land area is over 100 meters.

Steep slopes (incline over 40 percent) characterize as

much as 44 percent of the total area. Lakes are

relatively few and small, apart from the Iralalaru Lake

basin. Few of the approximately one hundred rivers

flow regularly throughout the year and some dry up

completely during the dry season. The largest river

system (80 km in length) is the Lois River, on the north

side of the mountains.

Climate varies greatly across Timor-Leste. The mean annual temperature at sea level is 27.5 °C and

19.8 °C at 1432 meters above sea level. The South coast is “permanently moist” with more than 2

meters of rain for 9 to 12 months per year. The northern part is “permanently dry” with rainfall of

500 to 1000 millimeters or more occurring in a four to six month wet season from December to May

or June. Hard torrential rain is common, with maximum daily rainfall recorded as high as 398

millimeters. This causes a high degree of surface runoff and increased soil erosion.

For more detailed information on the environment in Timor-Leste, see USAID/Timor-Leste’s 2012

CDCS IEE at http://www.usaid.gov/sites/default/files/documents/1870/cdcs-timor-leste-2013-

2018.pdf.

National Environmental Policies and Procedures

The Constitution of the Democratic Republic of Timor-Leste recognizes in Article 6 the importance

of the protection of the environment. Furthermore, Section #61 states that:

1. Everyone has the right to a humane, healthy, and ecologically balanced environment and the

duty to protect it and improve it for the benefit of the future generations.

2. The State shall recognize the need to preserve and rationalize natural resources.

3. The State should promote actions aimed at protecting the environment and

safeguarding the sustainable development of the economy.

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http://www.usaid.gov/sites/default/files/documents/1870/cdcs-timor-leste-2013-2018.pdf

http://www.usaid.gov/sites/default/files/documents/1870/cdcs-timor-leste-2013-2018.pdf

Section 139(3) addressing natural resources states “the exploitation of natural resources shall

preserve the ecological balance and prevent destruction of ecosystems” and Section 96(h) gives the

Parliament the authority to define “the bases for a policy on environmental protection and

sustainable development.”

The Constitution provides the greatest clarity on the importance of the environment to livelihoods

and national development; however, a national environmental policy has yet to be adopted.

The Government of Timor-Leste is currently drafting and approving several laws impacting the

environment and following are those relevant to “Timor-Leste Plastic Upcycling Alliance” project:

● Draft Zero Plastics Policy that aims at ensuring a single-use plastic free future for a cleaner and

greener Timor-Leste by 2030.

● The Environmental Basic Law No. 26/2012 aims for the conservation and improvement of

environmental quality, protection of human health, sustainable use of natural resources and

pollution control.

● Environmental Licensing Decree Law No.5/2011 regulates the environmental licensing system by

requiring procedures for environmental impact assessment and protection of traditional customs

and duties.

● The Protected Area Decree Law (drafted May 31, 2013- being circulated for comments) would

update UNTAET Regulation 2000/19.

● The Forestry Decree Law (drafted 2009-in process) targets sustainable management of forest

resources and watersheds to provide environmental, social and economic benefits to the people of

Timor-Leste.

● Wildlife Conservation Law (2011-proposed) – will protect and conserve wildlife in Timor-Leste.

● Law on Pesticides (2011- draft) – will register and regulate pesticides in Timor-Leste, though it

still remains as a draft after eight years.

● Laws and Policies on Fertilizer and Seeds (drafted 2009-in process)

Other laws that can impact incentives for natural resource conservation are Law No. 1/2003 and Law

No. 12/2005 which provide the general conditions for land ownership and Decree Law No. 19/2004

which defines state property ownership (MED, 2008). With the support of USAID, in 2009 the

Ministry of Justice drafted a new Land Tenure Law to define who does and does not own land and

who deserves compensation, but it was sent back to Parliament by the President. The Special Regime

for the Ownership of Immovable Property (Land Law) was finally approved by the Council of

Ministers on the 29th of March 2016 then by the National Parliament on the 6th of February 2017.

The Land Law No. 13/2017 was enacted by the President on June 1, 2017.

National Action Plans have been written for Combating Land Degradation (2008), Climate Change

Adaptation (2010), and Biodiversity (2012), and a National Ecological Gap Assessment was

conducted (2010). Currently, work is underway on the Program of Works on Protected Areas

(PoWPA). Timor-Leste became a signatory to the U.N. Framework Convention on Climate Change

in 2007 and in 2008 the National Parliament ratified the Kyoto Protocol. Timor-Leste plans to have a

Designated National Authority for the Mechanisms of the Kyoto Protocol and a National Climate

Change Centre by 2015. Timor-Leste is also part of the Coral Triangle Initiative (CTI), a partnership

effort among six Southeast Asian countries and several NGOs to conserve and protect marine

biodiversity.

D. EVALUATION OF ENVIRONMENTAL IMPACT

The following paragraphs discuss and evaluate the potential environmental impacts of the Plastics

Upcycling Alliance activities under each component.

There are eight activities that fall under authorities for Categorical Exclusions. They are: 2.2.1

Analyze global best practices and lessons for applicability to local context;

2.2.2 Conduct Market Analysis;

3.1.1 Hold regular meetings of upcycling industry actors and stakeholders;

3.1.2 Develop and implement plan of policy reforms for improving management of plastics;

3.2.1 Conduct baseline/end line analysis;

3.2.2 Refine agenda and conduct research and impact assessments important to activity efficacy;

3.3.1 Document model, lessons and recommendations for plastics management in small- to medium-

sized cities; and

3.4.1 Develop and implement strategic plan for communicating PUA lessons learned.

The following activities are under Negative Determination with Conditions:

2.2.3 Prototyping and testing of product line;

2.2.4 New upcycling technologies introduced;

2.3.1 Analyze and implement best options to increase product competitiveness and market share; and

2.3.2. Install demo roads, walkways, parking lots, etc.

Potential environmental impacts that can be mitigated include air pollution, water pollution and solid

waste disposal. Careful selection of sites will minimize the impact on environment and residents. In

addition, an Environmental Mitigation and Monitoring Plan (EMMP) will be prepared to ensure that

there will be proper monitoring and mitigation, and the EMMP will be approved by the

Agreement/Contracting Officer Representative (AOR/COR) with clearance from the Mission

Environmental Officer (MEO), prior to implementation for these activities.

A Corrective Action Plan will be required should any implementation problems arise. Further, a

USAID Regional Environmental Advisor is available to assist, should there be questions on process.

More details and other potential impacts to consider are highlighted in the relevant USAID sector

environmental guidelines found at the following site (until its relocation inside www.USAID.gov):

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

E. RECOMMENDED THRESHOLD DECISIONS

The table below provides additional descriptions for the potential environmental impacts and

recommended determinations and conditions for the activities listed in this IEE. Activities

implemented beyond those listed below will require an IEE amendment. Conditions referred to in the

table are listed below.

No. Activities Effect on Natural or

Physical Environment

Determination and Reg. 216

actions required

2.2.1 Analyze global best practices

and lessons for applicability

to local context

None Categorical Exclusion

2.2.2 Conduct Market Analysis


2.2.3 Prototyping and testing of

product line Yes Negative Determination with

Conditions:

● Provide protection

equipment to the

participants;

● Anticipative

measures taken to

mitigate noise

resulting from the

test;

● Residuals from the

http://www.usaid.gov/

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

testing disposed

properly and safely.

2.2.4 New upcycling technologies

introduced Yes Negative Determination with

Conditions:

● Measures taken to

ensure safety during

product development;


mitigate noise and

pollution resulting

from the product

development;


ensure a secure move

of products to the

market.

2.3.1 Analyze and implement best

options to increase product

competitiveness and market

share

Yes Negative Determination with

Conditions:

● Anticipative

measures taken to

ensure the best option

implemented

properly minimizing

impact on

environment and

people;

● Ensure that the

scenery for the

implementation of

the option is

unchanged;


minimize dust

resulting from the

demonstrations.

2.3.2 Install demo roads,

walkways, parking lots, etc

Yes Negative Determination with

Conditions:

● Anticipative

measures taken to

ensure safety in

setting-up the

demonstration sites;

● Ensure that the

scenery of the

demonstration sites is

unchanged;


minimize dust

resulting from the

demonstrations.

3.1.1 Hold regular meetings of

upcycling industry actors and

stakeholders

None

Categorical Exclusion

3.1.2 Develop and implement plan

of policy reforms for

improving management of

plastics


3.2.1 Conduct baseline/end line

analysis


3.2.2 Refine agenda and conduct

research and impact

assessments important to

activity efficacy


3.3.1 Document model, lessons and

recommendations for plastics

management in small- to

medium-sized cities


3.4.1 Develop and implement

strategic plan for

communicating PUA lessons

learned


Climate Risk Management

As per the ADS 201mal “Climate Risk Management for USAID Projects and Activities,” USAID must

factor climate resilience into international development programs and investments. Therefore, the design

team and/or implementing partner will identify expected climate change impacts over the life of the

activity’s expected benefits and (if appropriate) demonstrate how those risks will be reduced in order to

ensure sustainability of the activity’s objectives.

The activity-level Climate Risk Screening is below. This activity has been determined to have Low and

Moderate risk.

Climate Risk Screening – Timor-Leste Plastic Upcycling Alliance (PUA)

Tasks / Defined or

Illustrative Interventions

Climate Risks

Risk Rating

How Risks are Addressed

Opportunities to

Strengthen

Climate

Resilience

Task 1: Analyze global

best practices and lessons

for applicability to local

context

There are no significant

risks for the umbrella

task nor proposed

interventions.

Low - -

Task 2: Conduct Market

Analysis



task nor proposed

interventions.

Low - -

Task 3: Prototyping and

testing of product line

Increased intensity and

frequency of flooding

Moderate Proper site selection for testing

of product line to minimize the

impact of flooding.

-

Sea level rise Low Proper site selection for testing


impact from sea level rise.

Increased ocean salinity Low Proper site selection for testing


impact on ocean salinity.

Task 4: New upcycling

technologies introduced



Moderate Proper site selection for the

introduction of new upcycling

technologies to minimize the

impact of flooding.

-

Sea level rise Low Proper site selection for the



impact from flooding.

Increased ocean salinity Low Proper site selection for the



impact to ocean salinity

Task 5: Analyze and

implement best options

to increase product

competitiveness and

market share



task nor proposed

interventions.

Low

Task 6: Install demo

roads, walkways, parking

lots, etc



Moderate Proper site selection for the

demonstration to minimize the

risk and appropriate

engineering considering

climate implications to reduce

the potential impact of

flooding.

-

Sea level rise Low Proper site selection for the





the potential impact from sea

level rise.

Increased ocean salinity Low Proper site selection for the





the potential impact to ocean

salinity.

Task 7: Hold regular

meetings of upcycling

industry actors and

stakeholders



task nor proposed

interventions.

Low - -

Task 8: Develop and

implement plan of policy

reforms for improving

management of plastics



task nor proposed

interventions.

Low - -

Task 9: Conduct

baseline/end line analysis



task nor proposed

interventions.

Low - -

Task 10: Refine agenda

and conduct research and

impact assessments

important to activity

efficacy



task nor proposed

interventions.

Low - -

Task 11: Document

model, lessons and

recommendations for

plastics management in

small- to medium-sized

cities



task nor proposed

interventions.

Low - -

Task 12: Develop and

implement strategic plan

for communicating PUA

lessons learned



task nor proposed

interventions.

Low - -

Task 13: Quarterly

coordination meeting



Low - -

with all levels of

government

task nor proposed

interventions.

F. MONITORING AND REPORTING

1. Implementing Partner (IP) Briefings on Environmental Compliance Responsibilities. The

AOR/COR shall provide the IP with a copy of this IEE; the IP shall be briefed on their

environmental compliance responsibilities by their AOR/COR. During this briefing, the IEE

conditions applicable to the IP’s activities will be identified, including those identified in the

climate risk screening.

2. Development of Environmental Mitigation and Monitoring Plan. For activities that are

subject to one or more conditions set out in the “Recommended Threshold Decision” section of

this IEE, the IP shall develop and provide and EMMP for USAID AOR/COR review and

approval, documenting how their project will implement and verify all IEE conditions that apply

to their activities, including mitigation measures identified above in the climate risk screening.

The EMMP shall also identify how the IP shall assure that IEE conditions that apply to activities

supported under sub-grantee to develop their own EMMP.

3. Integration and implementation of EMMP. The IP shall integrate the EMMP into their project

work plan and budgets, implement the EMMP, and report on its implementation as an element of

regular project performance reporting.

The IP shall assure that sub-grantees integrate implementation of IEE conditions, where

applicable, into their own project work plans and budgets and report on their implementation as

an element of sub-grant performance reporting.

4. Implementing Team monitoring responsibility. As required by ADS 204.3.4, USAID will

actively monitor and evaluate whether there are new or unforeseen consequences arising during

implementation that were not identified and reviewed in accordance with 22 CFR 216. USAID

shall also monitor the need for additional review. If additional activities not described in this

document are added to this program, an amended environmental examination must be prepared

and approved.

5. New or modified activities. As part of its initial Work Plan, and all Annual Work Plans

thereafter, the IP, in collaboration with their AOR/COR, shall review all planned and ongoing

activities to determine if they are within the scope of this IEE.

If any IP activities are planned that would be outside the scope of this IEE, an amendment to this

IEE addressing these activities shall be prepared for USAID review and approval. No such new

activities shall be undertaken prior to formal approval of this amendment.

Any ongoing activities found to be outside the scope of the approved Regulation 216

environmental documentation shall be halted until an amendment to the documentation is

submitted and written approval is received from USAID. This includes activities that were

previously within the scope of the IEE, but were substantively modified in such a way that they

move outside of the scope.

6. Compliance with Host Country Requirements. Nothing in this IEE substitutes for or

supersedes IP, sub-grantee responsibility for compliance with

all applicable host country laws and regulations for all host countries in which activities will be

conducted under the USAID activity.

The IP, sub-grantees must comply with each host country’s environmental regulations unless

otherwise directed in writing by USAID. However, in case of conflict between host country and

USAID regulations, the latter shall govern.

G. LIMITATIONS:

This IEE does not cover activities involving:

1. Classes of actions normally having a significant effect on the environment pursuant to 22 CFR

216.2(d)(1):

i. Programs of river basin development;

ii. Irrigation or water management projects, including dams and impoundments;

iii. Agricultural land leveling;

iv. Drainage projects;

v. Large scale agricultural mechanization;

vi. Resettlement projects;

vii. New land development;

viii. Penetration road building and road improvement;

ix. Power plants;

x. Industrial plants; and

xi. Potable water and sewerage projects, other than those that are small scale.

2. Activities affecting threatened and endangered species.

3. Activities introducing exotic species.

4. Activities resulting in wetland or biodiversity degradation or loss.

5. Support to extractive industries (e.g. mining and quarrying).

6. Support for activities that promote timber harvesting.

7. Activities involving privatization of industrial or infrastructure facilities.

8. Assistance for the procurement (including payment in kind, donation, guarantees of credit) or use

(including handling, transport, fuel for transport, storage, mixing, loading, application, cleanup 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.

9. Procurement or use of genetically modified organisms.

10. DCA programs.

Any of the above actions would require an amendment to the IEE approved by the Bureau

Environmental Officer (BEO).

H. 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 information

becomes available that indicates that activities covered by the IEE might be considered “major” and

their effect “significant”, or if additional activities are proposed that might be considered “major” and

their effect “significant”, this recommendation for Categorical Exclusion will be reviewed and, if

necessary, an environmental assessment will be prepared. It is the responsibility of the USAID AOR

to keep the MEO and BEO informed of any new information or changes in the activity that might

require revision of the IEE.

John Wilsonon behalf of

7/15/2019

APPROVAL OF INITIAL ENVIRONMENT AL EXAMINATION:

CLEARANCES:

Miss ion Env ironmenta l Officer and Climate Integrat ion Lead:

Regional Legal Officer:

Reg iona l Env ironmen tal Advisor:

APPROVAL:

Mission Director

Diana B. Putman

CONCURRENCE:

Bu au Environmental OfNcer

Cleared via email Flavia A. da Silva

Cleared via emai l Ying Hsu

Cleared via ema il Mark Childerhose

Date :

Date: _______ _

Date: July 2, 2019

Date : July 9, 2019

Date: July 8, 2019

I ~, 2...6 1 9 l

Filename: __ _ ________ _ USAID /ASIA S EO

.1.J

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