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USAID AFGHANISTAN FROM THE AMERICAN PEOPLE

Office of Afghanistan & Pakistan Affairs (OAP A)

REQUEST FOR CATEGORICAL EXCLUSION

PROGRAM/ACTIVITY DATA

Country Code: Program Area: Assistance Objective: Intermediate Results: Country or Region:

306 Program Design and Leaming NIA NIA Afghanistan

Activity Name: Afghanistan Monitming, Evaluation, and Leaming Activity (AMELA)

Funding Period: Life of Project (LOP) Amount: IEE Prepared by: Date: IEE Amendment (YIN):

July 2017 to July 2022 75 million Troy Tillis, OPPD 8/2/2016 N

ENVIRONMENTAL ACTION RECOMMENDED:

Categorical Exclusion

Positive Dete1mination Negative Dete1mination With Conditions

Climate Change Vulherability Risk

[X] [ ] [ ]

None [X]

Defe1rnl

Negative Dete1mination Exemption

Low [] Medium [ ]

1.0 PURPOSE, BACKGROUND AND ACTIVITY DESCRIPTION

1.1. Purpose and Background

[ ] [ ] [ ]

High [ ]

The purpose of this IEE is to provide threshold dete1minations for the proposed Afghanistan Monitoring, Evaluation, and Leaming Activity (AMELA), which will serve as USAID/Afghanistan's central monitoring and evaluation (M&E) suppo1i services. mechanism.

The IEE provides a brief statement of the factual basis for the Threshold Decision whether an Environmental Assessment or an Environmental Impact Statement is required for the subject activity.

1.2. Activity Description

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In order to meet development results, ensure accountability for the USG resources, and make programmatic improvements as a result of lessons learned, the ADS requires USAID Missions to have comprehensive perfo1mance management, planning, monitoring, evaluation and learning systems. The purpose of strong perfmmance monitoring and evaluation is to apply the learning and evidence gained from analysis to make choices regarding program design and implementation, and to credibly document program effectiveness.

AMELA will assist USAID/Afghanistan in achieving the Agency's vision for strengthened monitoring, evaluation, and learning by achieving the four service components outlined below:

1. Evaluation Technical Support Services - Providing comprehensive evaluation and assessment services, including mid-te1m and final evaluations, performance and impact evaluations, geographic and sectoral assessments, activity-specific assessments and verifications, gender analyses, sustainability analyses, etc - for USAID at multiple design and implementation levels (e.g., activity, project, etc.), and in all sectors in which the Mission works;

2. Monitoring Technical Support Services - Ensuring third paiiy monitoring (TPM) coverage that compliments the Mission's MTM approach (Tier 5) through, but not limited to, field-based data collection, verification, and data quality assessments.

3. Learning and Adaptive Management Services - Suppmiing development and operationalization of the Mission's CLA Strategy which includes integration with the MSP T04 knowledge management platform and M&E findings related to the operational environment, monitoring, and evaluation; and

4. Program Support Services -Focusing on M&E related short te1m assistance to supp01i Mission-wide strategic planning and alignment effmis, such as a Country Development Cooperation Strategy, Performance Management Plan, and indicator development and alignment.

2.0 COUNTRY AND ENVIRONMENTAL INFORMATION1

2.1 Locations Affected

AMELA monitoring, evaluation, and assessment activities will take place throughout Afghanistan. However, the implementing partner will maintain a central office based in Kabul, Afghanistan. No additional, regional offices will be managed or maintained. Activities and work commissioned under the AMELA award will require travel to regions where monitoring, evaluation, and assessment work will be completed. There are no environmental effects of the monitoring, evaluation, and assessment work completed at the provincial, district, or village level.

1 Please see: http://www-wds.worldbank.org/extemal/default/WDSContentServer/WDSP/IB/2010/04/ 12/000333037 20 I 0041200 I 029/R endered/PDF/52211 OESWOWhitl anistanOFinalOReport.pdf; http://www­wds.worldbank.org/extemal/default/WDSContentServer/WDSP/IB/2011 /01/11 /000333037 20110111004513/R endered/PDF/E26350SARI EA IP I Box353824B01PUBLIC l .pdf; http://www­wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2010/l l/16/000334955 20I0111 6014820/R endered/PDF/ E25860EAOP 12031 Frameworklappraisal.pdf;

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2.2 Socio-economic baseline

Afghanistan is located in Central Asia, north and west of Pakistan, and east of Iran. Afghanistan's economy has improved significantly since the fall of the Taliban regime in 2001 largely because of the infusion of international assistance, the recovery of the agricultural sector, and service sector growth. Despite the progress of the past few years,

Afghanistan is extremely poor, landlocked, and highly dependent on foreign aid, agriculture, and trade with neighboring countries (Table 1). Much of the population continues to suffer from shortages of housing, clean water, electricity, medical care, and jobs. Insecurity and the

Afghan government's inability to extend rule of law to all patis of the country pose challenges to future economic growth. It is expected to take the remainder of the decade, and continuing donor aid and attention, to significantly raise the average Afghan's living standards from its current level, which is among the lowest in the world. While the international community remains committed to Afghanistan's development, pledging over $24 billion at three donor conferences since 2002, Kabul will need to overcome a number of challenges, including expanding poppy cultivation, budget sustainability, job creation, corruption, government capacity,. and rebuilding war torn infrastructure.

Degradation of the environment and depletion of natural resources are significant and visual consequences of the long period of instability, including depletion of forest cover by 66.5 percent in the south-eastern part of the country over the last 30-year period. Wood is still the main source of energy for over 90 percent of households. Despite the country's challenges,

the Afghan government, the United States, and international donors are committed to improving access to basic necessities by prioritizing infrastructure development, education, housing development, jobs programs, and economic reform. Reconstruction projects include national and provincial road constrnction, water management studies, and alternative power initiatives like micro-hydro power stations.

2.1 Policy, Legal and Regulatory Framework and International Conventions

The primary relevant laws and legislations framing social and environmental issues are: The

Environment Law of Afghanistan (2007), the Land Expropriation Law (2005), the Water Law (2004), and the Law on the Preservation of Afghanistan's Historical and Cultural Heritages (2004).

Afghanistan is a party to international agreements on Biodiversity, Climate Change, Dese1iification, Endangered Species, Environmental Modification, Marine Dumping, and Ozone Layer Depletion. The country also signed the agreement for Hazardous Waste which was recently ratified.

2.2 Environment Law of Afghanistan, 2007

The Environment Law requires the Afghan government to adopt necessary measures to protect natural forests and living conditions of the country. The National Environmental Protection Agency (NEPA) is responsible for the implementation of this law. Following international best practices, NEPA mandates that new activities are screened for potential

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adverse effects and possible impacts and, if such impacts are likely, a comprehensive mitigation plan is developed for review and approval before the activity can proceed.

In June 2009 NEPA issued the first Afghanistan list of the protected species, which included 46 species.

2.3 Land Expropriation Law (LLE), 2005

The LLE sets out the provisions governing the expropriation or acquisition of land for public

interest purposes, such as the establishment/constrnction of public infrastrncture or for acquisition of land with cultural or scientific values, land of higher agricultural productivity and large gardens. It declares, inter alia, that: a) acquisition of a plot or pmtion of a plot of land for public use is decided by the Council of Ministers and is compensated at fair value based on current market rates (A1ticle 2); b) the right of the owner or land user will be terminated three months prior to the sta:tt of civil works on the project and after the proper reimbursement to the owner or person using the land has been made (A1ticle 6); c) the value of land, value of houses and buildings on the land and value of trees and other assets on the land will be considered for compensation (Alticle 8); and f) compensation is determined by the Council of Ministers. The Law, however, is silent on resettlement. It makes no special provision for a resettlement plan or indeed any anangements for resettlement.

2.4 Water Law, 2004

The Water Law lays out a model for managing Afghanistan's water resources following the

principles of Integrated Water Resources Management (IWRM). The law calls for a nested governance structure for water resources decision-making, including pa:tticipatory models of community-based management through Water User Associations (WUAs) and Irrigation Associations (lAs), operating within a decision-making framework of River Basin Authorities (RBAs) and River Basin Councils (RBCs) in the five major river basins and 4I sub-basins of

the country. It sets out requirements for sustainable water allocation and use, and establishes sanctions and penalties for noncompliance.

2.5 Law on Preservation of Afghanistan's Historical and Cultural Artifacts, 2004

According to The Law on the Preservation of Afghanistan's Historical and Cultural Altifacts, operations that cause destruction or hmm to the recorded historical and cultural sites or a:ttifacts is prohibited (Alt . I I, Art. I 6). The law provides guidelines for how to deal with historical and cultural a:ttifacts if they ai·e discovered.

Table 1. Selected data for Afghanistan

Socio-Economic Data Natural Resources/Environment Data

%of

Total Population- 35.32 million (in 2011) Land use hectares total

3,302,007 5.1 1 %

Population Growth Rate (annual %)- 2.03 Irrigated

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agricultural land

Urban Population(% of total)- 5.69 million Orchards (21.9%)

94,217 0.15%

Rain-fed

Agricultural Land 4,517,714 7.00% Life Expectancy (years)- 49

Forest Area 1,337,582 2.07%

Infant M011ality Rate (per 1,000 live births)- 111 Total Pashire Area 29,176,732 45.19%

Total Land Other-

GDP (current$)- 19.5 billion (2011) Arid/Dese11 26, 13] ' 144 40.48%

Total Land Area 64,559,396

GDP breakdown: Agriculture 34.9 %, Industry 25

% Population Density- 54.70 persons/km2 (in 2011)

Services- 40 %

GDP Growth (annual%)- 8.5 I

Livestock: Cattle: 3.72 million, Sheep: 8.77 million

Inflation (annual%)- 4.8 Goats: 7.28 million

Unemployment Rate (annual%)- 35 Deforestation Rate(% of change)- 66.5 % (1971-1999)

Improved Water Source(% of pop. with access)-42%

Electricity Consumption - 2.226 billion kWh (2009 est.)

3.0 RECOMMENDED THRESHOLD DECISIONS AND MITIGATION ACTIONS

Below are the recommended actions for the activities described above, their impacts on the environment and recommended Threshold Dete1minations and Conditions, if any:

Activity Effects on natural or Recommended Threshold Determination

physical environment Implementing Partner will No effect on the natural or Categorical Exclusions, no action required per conduct research, physical environment 22 CFR 216.2( c)(2)(i), (ii), (iii), (v) and (xiv) evaluations, assessments, surveys, and monitoring visits which will be used to develop analysis and

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Table 1 - Proposed activities and recommended threshold decisions for the AMELA mechanism.

4.0 ENVIRONMENTAL RECOMMENDATIONS

Recommended Action: Categorical Exclusions (ca. 100% of funding)

AMELA activities fall under four main components (Evaluation Technical Services; Monitoring Technical Services; Learning and Adaptive Management Services; and Program Support Services), do not have an effect on the natural and physical envirnnment fit within the categories listed in 22 CFR 216.2 (c)(2), and are otherwise categorically excluded from any further environmental review requi.J:ements. The originator of the proposed action has determined that the proposed activities are within the following classes of actions:

• Education, technical assistance, or training programs, except to the extent such programs include activities directly affecting the environment (such as construction of facilities, etc.) [22 CFR 216.2(c)(2)(i)];

• 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)]; ;

• Analyses, studies, academic or research workshops and meetings. [22 CFR 216.2( c )(2)(iii)];

• Document and info1mation transfers. [22 CFR 216.2(c)(2)(v)]; and • Studies, projects or programs intended to develop the capability of recipient

countries to engage in development planning, except to the extent designed to result in activities directly affecting the environment (such as construction of facilities, etc.). [22 CFR 216.2(c)(2)(xiv)].

5.0 LIMITATIONS OF THE RCE

This RCE does not cover the following:

• Assistance, procurement or use of genetically modified organisms (GMOs) will require preparation of biosafety assessment (review) in accordance with ADS 201.3.12.2(b) in an amendment to the RCE approved by OAPA BEO.

• DCA or GDA programs. • Procurement or use of Asbestos Containing Materials (ACM) (i.e. piping, roofing,

etc.), Polychlorinated Biphenyl (PCB) containing transfo1mers, or other hazardous/toxic materials for construction projects, including lead and mercury.

• Procurement, use, or recommendation for use of pesticides both in agriculture and construction. The contracto\· shall prepare a Pesticide Evaluation Report and Safer Use Action Plan (PERSUAP) or see which existing valid PERSUAPs can be amended for the purpose of the proj ect.

• Procurement or use of Ammoniun1 Nitrate (AN) and Calcium Ammonium Nitrate (CAN) fertilizers.

• Procurement of use of asbestos and lead based paint.

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Any of these actions would require an amendment to the RCE and the BEO/OAP A approval by the BEO/OAP A.

6.0 REVISIONS

Pursuant to 22 CFR 216.3(a)(9), if new infmmation becomes available which indicates that activities to be funded by the project might be "major" and the project's effect "significant," or if additional activities are proposed that might be considered "major" and their effects significant, this RCE will be reviewed and revised by the originator of the project and

submitted to the BEO/OAP A for approval and, if appropriate, an environmental assessment will be prepared. It is the responsibility of the USAID COR/AOR to keep the Mission Environmental Officer, USAID/ Afghanistan and the BEO/OAP A informed of any new

information or changes in scope and nature of the activity that might require revision of the RCE.

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APPROVAL OF RECOMMENDED ENVIRONMENT AL ACTIONS

Afghanistan Monitoring, Evaluation, and Learning Activity (AMELA), RCE

A/COR, OBM, Activity Manager

Acting Office Director, OPPD

Mission Environmental Officer

Regional Environmental Advisor/Asia & OAPA

Acting RLO Office Director

Acting Deputy Mission Director

Mission Director

Acting Bureau Environmental Officer for Afghanistan and B EO for ME

DISTRIBUTION: MEO, CORIAOR, OAA, RLO

Clearances:

Cleared by Email Troy Tillis

Cleared by Email Oghale Oddo

Cleared by Email Harry Bottenberg

Cleared by Email Andrei Barannik

John 'Greg' Butler

Kent Larson

Herbert Smith

Approval:

John Wilson

Date:

8/7/2016

8/9/2016

8/4/2016

8/8/2016

Date:

8

APP ROY AL OF RECOMMENDED ENVIRONMENTAL ACTIONS

Afghanistan Monitoring, Evaluation, and Learning Activity (AMELA), RCE

J\/COR, OBM, Activity Manager

/\cling Office Director, OPPD

Mission Environmental Ollicer

Regional Environmental Advisor/Asia & OAP/\

/\cling RLO Office Director

Acting Deputy Mission Director

Mission Director (A)

/\cling Bureau Environmental Officer for Alghanistnn and BEO for ME

DISTRlBUTION: MEO, COR/AOR, OAA, RLO

Clcarnnces:

Cleared by Email Troy Tillis

Cleared bv Email Oghale Oddo

Cleared by Email 1-lnrry Bottcnbcrg

Cleared by Email Andrei l3arnnnik

Date:

81712016

8/9/2016

8/4/2016

8/8/2016

f/11/16

Date:

8/8/2016 USAID M ai l - Re: [REVIEW] AMELA Categorical Exclusion Request

Mohammad Mustafa Sultani <msul tani@usaid.gov>

Re: [REVIEW] AMELA Categorical Exclusion Request 1 message

Troy Tillis <ttillis@usaid.gov> Sun, Aug 7, 2016 at 3:48 PM To: Harry Bottenberg <hbottenberg@usaid.gov> Cc: Mohammad Mustafa Sultani <msultani@usaid.gov>, Andrei Barannik <abarannik@usaid.gov>, Alexandria Huerta <ahuerta@usaid.gov>

Thanks gentlemen. I clear as well. Appreciate your ass istance in moving this through the,additional layers of approval.

Best, Troy

TROY TILLIS Evaluation, Data, and Leaming Team Lead Office of Program and Project Development (OPPD) USAID I Afghanistan Mobile: +93 (702) 32-3274

Office: +1 (301) 490-1042, ext 3922

On Sun, Aug 7, 2016 at 3:43 PM, Harry Bottenberg <hbottenberg@usaid.gov> wrote: I clear.

harry

On Sun, Aug 7, 2016 at 2:22 PM, Mohammad Mustafa Sultani <msultani@usaid.gov> wrote: Dear Troy,

Please find attached final AMELA RCE for your review and clearance. The clearance process will take approximately one week.

Best Regards, Regards,

On Sun, Aug 7, 2016 at 2:01 PM, Troy Tillis <ttillis@usaid.gov> wrote: Harry and Mustafa,

Please confirm receipt of the updated Categorical Exclusion memo for the AMELA award. Also, what is the normal timeline for review and approval?

Many thanks for the follow-up.

Best, Troy

TROY TILLIS Evaluation, Data, and Leaming Team Lead Office of Program and Project Development (OPPD) USAID I Afghanistan Mobile: +93 (702) 32-3274

Office: +1 (301) 490-1042, ext 3922

On Tue, Aug 2, 201 6 at 1 :58 PM, Troy Tillis <ttillis@usaid.gov> wrote: Harry,

Thanks for sending me the new format/template. Please find attached, the new Categorical Exclusion memo

https://mail.google.com/mail/u/O/?ui=2&ik=23c2ea92c4&view=pt&as_subj=AMELA&as_sizeoperator=s_sl&as_sizeunit=s_smb&as_subset=all&as_within=1d&.. . 1/6

8/10/2016 USAID Mail - Re: [REVIEW) AMELA Categorical Exclusion Request

Mohammad Mustafa Sultani <msultani@usaid.gov>

Re: [REVIEW] AMELA Categorical Exclusion Request 1 message

Oghale Oddo <ooddo@usaid.gov> Tue, Aug 9, 2016 at 6:05 PM To: Mohammad Mustafa Sultani <msultani@usaid.gov> Cc: Troy Tillis <ttillis@usaid.gov>, Volodymyr Yatsenko <vyatsenko@usaid.gov>, Andrei Barannik <abarannik@usaid.gov>, Harry Bottenberg <hbottenberg@usaid.gov>

Cleared . Thank you . Oghale

Office of Program and Project Development (OPPD)

USAID Afghanistan

NOX Room 5501

301 490 1042 X3125

Mobile: Mobile: +93 ( 701) -111-6794

On Tue, Aug 9, 2016 at 2:00 PM, Mohammad Mustafa Sultani <msultani@usaid.gov> wrote: Hello Oghale,

Please find attached RCE for AMELA for your review and clearance. Thanks .

Best Regards, Mustafa

On Mon, Aug 8, 2016 at 12:30 PM, Harry Bottenberg <hbottenberg@usaid.gov> wrote: Ok, Mustafa, go ahead and edit as I suggested and continue the mission c learance process.

I c lear.

Harry

Sent from my iPhone

On Aug 8, 2016, at 11 :30 AM, Troy Tillis <tti ll is@usaid.gov> wrote:

The document in your possession is editable. We're ok if Mustafa just puts in the language required. Easier and more efficient than pass ing different versions around. Update as you guys see fit.

Thanks, Troy

TROY TILLIS Evaluation, Data, and Leaming Team Lead Office of Program and Project Development (OPPD) USAID I Afghanistan Mobile: +93 (702) 32-3274

Office: +1 (301) 490-1042, ext 3922

On Mon, Aug 8, 2016 at 11 :28 AM, Harry Bottenberg <hbottenberg@usaid.gov> wrote: Just put 75 million on the form followed by exact amount to be determined.

Sent from my iPhone

On Aug 8, 2016, at 8:20 AM, Troy Tillis <ttillis@usaid.gov> wrote:

https://mail.google.com/mail/u/O/?ui=2&ik=23c2ea92c4&view=pt&search=inbox&th=1566f84dbffaa8cb&siml=1566f84dbffaa8cb 1/9

8/7/2016 USAID Mail - Fwd: [REVIEW] AMELA Categorical Exclusion Request

Mohammad Mustafa Sultani <msultani@usaid.gov>

Fwd: [REVIEW] AMELA Categorical Exclusion Request 1 message

Harry Bottenberg <hbottenberg@usaid.gov> To: Mohammad Mustafa Sultani <msultani@usaid.gov> Cc: Andrei Barannik <abarannik@usaid.gov>

Thu, Aug 4, 2016 at 8:49 AM

Pis add climate change to the front sheet. Take out the green shading and check the formatting etc.

I clear.

This is in the OPPD I future folder. I tried to save it under a shorter name RCE AMELA but not sure if it was saved (the version currently there may be an older one).

Andrei, can you clear?

harry ---------- Frnwarded message ---------­From: Troy Tillis <ttillis@usaid.gov> Date: Tue, Aug 2, 2016 at 1:58 PM Subject: [REVIEW] AMELA Categorical Exclusion Request To: Harry Bottenberg <hbottenberg@usaid.gov> Cc: Mohammad Mustafa Sultani <msultani@usaid.gov>, Andrei Barannik <abarannik@usaid.gov>, Alexandria Huerta <ahuerta@usaid.gov>

Harry,

Thanks for sending me the new format/template. Please find attached, the new Categorical Exclusion memo request for the Afghanistan Monitoring, Evaluation, and Learning Activi ty (AMELA). Please let me know if you require any further information. I left the green highlighted areas green, but updated everything required by me (yellow highlight).

Best, Troy

TROY TILLIS Evaluation, Data, and Learning Team Lead Office of Program and Proj ect Development (OPPD) USAID I Afghanistan Mobile: +93 (702) 32-3274

Office: +1 (301) 490-1042, ext 3922

On Tue, Aug 2, 2016 at 8:54 AM, Harry Bottenberg <hbottenberg@usaid.gov> wrote: Hi Troy, can you pis use the attached IEE/RCE template. What you used is way too old. Yellow is text you need to fill in, green is boilerplate. We will still add Climate Risk, don't worry about that for now.

Mustafa can help with this if you're busy.

harry

On Sun, Jul 31 , 2016 at 5:22 PM, Troy Tillis <tti llis@usaid.gov> wrote: Harry,

Please find attached, the DRAFT SOW for the Afghanistan Monitoring, Evaluation, and Learning Activity (AMELA). It is still in concept phase, but aside from a few small changes here and there, we don't anticipate the SOW deviating terribly far from its current version.

The IEE is based on the approved IEEs for the predecessor awards to AMELA (SUPPORT I and SUPPORT II). Having said that, this shouldn't be a terribly challenging review as both of those awards had Categorical Exclusions

https://mail.google.com/mai l/u/O/?ui=2&ik=23c2ea92c4&view=pt&as_subj=Amela&as_sizeoperator=s_sl&as_sizeunit=s_smb&as_subset=all&as_w ithin=1d&s... 1/5

8/8/2016 USAID Mail - Fwd: [REVIEW) AMELA Categorical Exclusion Request

Mohammad Mustafa Sultani <msultani@usaid.gov>

Fwd: [REVIEW] AMELA Categorical Exclusion Request 1 message

Harry Bottenberg <hbottenberg@usaid.gov> To: Troy Tillis <ttill is@usaid.gov> Cc: Mohammad Mustafa Sultani <msultani@usaid.gov>

Troy, do you have a dollar amount for the funding level?

---------- Forwarded message ----------From: Andrei Barannik <abarannik@usaid.gov> Date: Sun, Aug 7, 2016 at 5:1 1 PM Subject: Re: [REVIEW] AMELA Categorical Exclusion Request To: Harry Bottenberg <hbottenberg@usaid.gov>

Pis find attached edits and simplification - with this I clear

On 7 August 2016 at 17:02, Harry Bottenberg <hbottenberg@usaid.gov> wrote: Here you go.

---------- Forwarded message ----------From: Mohammad Mustafa Sultani <msultani@usaid.gov> Date: Sun, Aug 7, 2016 at 2:22 PM Subject: Re: [REVIEW] AMELA Categorical Exclusion Request To: Troy Tillis <tti llis@usaid.gov>

Mon, Aug 8, 2016 at 7:47 AM

Cc: Harry Bottenberg <hbottenberg@usaid.gov>, Andrei Barannik <abarannik@usaid.gov>, Alexandria Huerta <ahuerta@usaid.gov>

Dear Troy,

Please fi nd attached final AMELA RCE for your review and clearance. The clearance process will take approximately one week.

Best Regards, Regards,

On Sun, Aug 7, 2016 at 2:01 PM, Troy Tillis <ttill is@usaid .gov> wrote: Harry and Mustafa,

Please confirm receipt of the updated Categorical Exclusion memo for the AMELA award. Also, what is the normal timeline for review and approval?

Many thanks for the follow-up.

Best, Troy

TROY TILLIS Evaluation, Data, and Leaming Team Lead Office of Program and Project Development (OPPD) USAID I Afghanistan Mobile : +93 (702) 32-3274

Office: +1 (301) 490-1042, ext 3922

https://m ail .google.com/mail/u/O/?ui=2&ik=23c2ea92c4&view=pt&as_subj=AM ELA&as_sizeoperator=s_sl&as_sizeunit=s_smb&as_subset=all&as_within=1d&... 1/6

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